Connecting Economies Through CBDC 

Connecting Economies Through CBDC

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Connecting Economies Through CBDC

Project mBridge experiments with cross-border payments using a common platform
based on distributed ledger technology (DLT) upon which multiple central banks can
issue and exchange their respective central bank digital currencies (multi-CBDCs).
The proposition of mBridge is that an efficient, low-cost and common multi-CBDC
platform can provide a network of direct central bank and commercial participant
connectivity, greatly increasing the potential for international trade flows and crossborder business at large. To test this proposition, a new native blockchain – the
mBridge ledger – was custom-designed and developed by central banks for central
banks, to serve as a specialised and flexible platform implementation for multicurrency cross-border payments. Particular attention was paid to modular
functionality, scalability, and compliance with jurisdiction-specific policy and legal
requirements, regulations and governance needs. The platform design ensures that
mBridge adheres to the five overarching CBDC principles emphasised by the
CPMI/BIS Innovation Hub/IMF/World Bank report to the G201: do no harm,
enhancing efficiency, improving resilience, assuring coexistence and interoperability
with non-CBDC systems and enhancing financial inclusion.
Over the course of six weeks, the mBridge platform was put to the test
through a pilot involving real-value transactions centred around the chosen use case
of international trade. Significant groundwork was laid prior to the pilot, including
extensive coordination within and among central banks and commercial banks, and
tailored legal agreements and dress rehearsals, which ultimately led to its success.
Between 15 August and 23 September 2022, 20 commercial banks from Hong Kong
SAR, Mainland China, the UAE and Thailand conducted payment and foreign
exchange (FX) payment versus payment (PvP) transactions on behalf of their
corporate clients using the CBDCs issued on the mBridge platform by their
respective central banks. The pilot advances multi-CBDC experimentation by settling
real value directly on the platform and on behalf of corporate customers. Over
US$12 million was issued on the platform, facilitating over 160 payment and FX PvP
transactions totalling more than US$22 million in value.
The pilot’s real-world setting also brought to light a range of policy, legal
and regulatory considerations of a multi-CBDC, cross-border payments platform
such as mBridge. Extending access to central bank money directly to foreign
participants and conducting transactions on a shared ledger requires further
exploration of policy, data privacy and governance considerations. A new, digital
form of currency and a multi-CBDC platform also raise challenging legal questions
that depend on each participating jurisdiction’s standing rules and regulations and
may require regulatory changes to achieve full legal certainty and clarity. While
some of these considerations can be addressed by the platform’s current design,
others require further development and exploration.

1

4

BIS et al (2022).

Project mBridge: Connecting economies through CBDC

Equipped with the lessons from earlier phases of the project, the pilot and
policy, legal and regulatory analysis, Project mBridge will continue the technologybuild and testing. This includes improving on existing functionalities and adding new
functionalities to the platform, as it continues to progress towards a minimum viable
product (MVP) and, eventually, a production ready system.

5

Project mBridge: Connecting economies through CBDC

2. Acronyms and abbreviations

6

AED

United Arab Emirates dirham

AML

anti-money laundering

API

application programming interface

BFT

Byzantine fault tolerance

BIS

Bank for International Settlements

BOT

Bank of Thailand

CBDC

central bank digital currency

CBUAE

Central Bank of the United Arab Emirates

CLS

continuous linked settlement

CNY

Chinese yuan

CPU

central processing unit

CTF

counter-terrorist financing

DLT

distributed ledger technology

EMDEs

emerging markets and developing economies

e-AED

United Arab Emirates dirham CBDC

e-CNY

Chinese yuan CBDC

e-HKD

Hong Kong dollar CBDC

e-THB

Thai baht CBDC

FX

foreign exchange

GDP

gross domestic product

HKC

Hong Kong Centre

HKD

Hong Kong dollar

HKMA

Hong Kong Monetary Authority

KYC

know your customer

mBL

mBridge ledger

MVP

minimum viable product

PBC

People’s Bank of China

PBCDCI

Digital Currency Institute of the People’s Bank of China

PoC

proof of concept

PvP

payment versus payment

RTGS

real-time gross settlement

SaaS

software as a service

THB

Thai baht

UAE

United Arab Emirates

UAT

user acceptance testing

UI

user interface

Project mBridge: Connecting economies through CBDC

3. Introduction
The G20 has made enhancing cross-border payments a global priority and has
identified CBDC as a potential way forward to improving such payments.2,3 A “holy
grail” solution for cross-border payments is one which allows such payments to be
immediate, cheap, universally accessible and settled in a secure settlement medium.4
For wholesale payments, central bank money is the preferred medium for financial
market infrastructures.5 A multi-CBDC platform upon which multiple central banks
can issue and exchange their respective CBDCs is a particularly promising solution
for achieving this vision, and mBridge is a wholesale multi-CBDC project that aims to
advance towards this goal. It builds on previous work done in Inthanon-LionRock
Phases 1 and 2 (Bank of Thailand and Hong Kong Monetary Authority (2020) and BIS
Innovation Hub et al (2021a)). It also applies the lessons learnt from other crossborder CBDC projects such as Jasper-Ubin (Bank of Canada and Monetary Authority
of Singapore (2019)), Stella (European Central Bank and Bank of Japan (2019)), Aber
(Saudi Central Bank and Central Bank of the United Arab Emirates (2020)), Jura
(BISIH et al (2021b)) and Dunbar (BISIH et al (2022)).
Project mBridge tests the hypothesis that an efficient, low-cost, real-time
and scalable cross-border multi-CBDC arrangement can provide a network of direct
central bank and commercial participant connectivity and greatly increase the
potential for international trade flows and cross-border business at large. More
specifically, it seeks to build an MVP, and move towards a production setting that:
i.

Improves solutions for the key pain points of international payments.

ii.

Advances cross-border settlement in central bank money.

iii.

Supports the use of local currencies in international transactions.

iv.

Creates opportunity for new and innovative payment products and
services.

All the while safeguarding currency sovereignty and monetary and financial stability
by appropriately integrating policy, regulatory and legal compliance, and privacy
considerations.
To achieve this, mBridge adopts a single-platform, direct-access CBDC
model – a common technical infrastructure hosting multiple CBDCs, on which local

2

Cross-border payments refer to payments that take place between a payer and a payee who are residents
of different jurisdictions and may be made in the currency of the payer’s jurisdiction or in another currency.
They form a subset of international payments, which also include offshore payments and domestic
payments made in foreign currency. See BISIH (2022).

3

In October 2020, the G20 endorsed a roadmap to enhance cross-border payments, comprising of the
necessary elements of a globally coordinated response in the form of a set of 19 building blocks (BBs). BB
19, in particular, is tasked with factoring an international dimension into CBDC design to explore how
CBDCs could potentially enhance cross-border payments. See FSB (2020) and BIS et al (2022).

4

See Bindseil and Pantelopoulos (2022) and BIS (2021).

5

See CPMI-IOSCO (2012).

7

Project mBridge: Connecting economies through CBDC

and foreign financial institutions can directly hold and transact in CBDCs issued by
central banks, irrespective of jurisdiction. The platform’s design adheres to five
important overarching criteria for assessing cross-border CBDC arrangements based
on CBDC principles developed in BIS et al (2020) and G7 (2021) – namely, do no
harm, enhancing efficiency, increasing resilience, assuring coexistence and
interoperability with non-CBDC systems and enhancing financial inclusion.6 mBridge
uses custom-built DLT to support real-time, peer-to-peer, cross-border payment
and foreign exchange (FX) transactions through a payment versus payment (PvP)
arrangement7 using CBDCs. Thereby, it offers potential improvements in terms of
speed, transparency, efficiency, resilience, access, costs and settlement-risk
reduction compared with the existing correspondent banking model. Given its
common platform, mBridge also achieves, by design, interoperability between
domestic traditional clearing systems as participants from multiple jurisdictions can
directly reach each other on a single, integrated technical platform.8 Access to CBDC
and modules for connecting to existing payment systems can also foster greater
financial inclusion for jurisdictions that are experiencing a decrease in active
correspondent banking links or decreased transaction flows.9
mBridge is a joint project between the BIS Innovation Hub Hong Kong
Centre (HKC), and four participating central banks in Asia and the Middle East – the
Hong Kong Monetary Authority (HKMA), the Bank of Thailand (BOT), the Central
Bank of the United Arab Emirates (CBUAE) and the Digital Currency Institute of the
People’s Bank of China (PBCDCI). These five entities make up the Steering
Committee for Project mBridge, which is chaired by the BIS Innovation Hub HKC and
supported by four subcommittees – Technology, Legal, Policy and Business –
chaired by the PBCDCI, HKMA, BOT and CBUAE, respectively. Steering Committee
members have decision-making and voting rights on the project and jointly lead the
platform design and development.
Individual experimentation with CBDCs by the HKMA, BOT, CBUAE and
PBCDCI date back several years. mBridge, in particular, is the third phase of a
cross-border multi-CBDC project that began in 2019 (Graph 1). The first phase,
Inthanon-LionRock Phase 1, was launched in 2019 when the HKMA and BOT joined
their CBDC efforts together to produce a proof of concept (PoC) single-corridor
network built on Corda, designed to allow Hong Kong SAR and Thailand commercial
banks to conduct fund transfers and FX transactions on a peer-to-peer basis in
Hong Kong dollar (HKD) and Thai baht (THB) wholesale CBDCs. This was followed by
Inthanon-LionRock Phase 2 in 2020–21, during which a prototype built on
Hyperledger Besu was developed and a third hypothetical jurisdiction was added.

6

As a single-system, direct-access CBDC model with a flexible modular framework to accommodate
jurisdiction-specific policy, legal and regulatory considerations, mBridge offers potential benefits in respect
of all five criteria compared with other CBDC frameworks. See BIS et al (2022) for a detailed discussion of
the five overarching CBDC criteria and different access and interoperability options of CBDC systems to
facilitate cross-border payments.

7

PvP is a settlement mechanism that ensures that the final transfer of a payment in one currency occurs if
and only if the final transfer of a payment in another currency or currencies takes place. See Committee on
Payments and Infrastructure, Glossary, October 2016, https://www.bis.org/cpmi/publ/d00b.htm.

8

See Boar et al (2021).

9

See Rice et al (2020).

8

Project mBridge: Connecting economies through CBDC

These early phases demonstrated the potential of a substantial improvement in
cross-border transfer speed and cost compared with the correspondent banking
model.10,11
mBridge journey

Graph 1

When the BIS Innovation Hub HKC, the PBCDCI and the CBUAE joined in
2021, the project entered Phase 3 and was renamed “mBridge”. Although earlier
phases of mBridge showed the potential of using CBDCs built on DLT for delivering
24/7, real-time, cost-effective and secure cross-border payments and settlements,
moving out of a simulated environment to a more real-world setting was needed for
a multi-CBDC platform to become an MVP. As a result, a new, fit-for-purpose private
permissioned blockchain was developed – the mBridge ledger – built by central
banks, for central banks.12 Special attention was paid to modular functionality,
scalability and compliance with jurisdiction-specific policy and legal requirements,
regulations and governance needs.
To maximise the value to the central banking community and project
transparency, other central banks were invited to join the project as observers. To
date, Project mBridge has welcomed observing members from around the world
including Bangko Sentral ng Pilipinas, Bank Indonesia, Bank Negara Malaysia, Bank
of Israel, Bank of Korea, Sveriges Riksbank, and staff of the Eurosystem Centre of the

10

There are various stages of a project starting from ideation to when it is brought to production comprising
of PoC, prototype, pilot and MVP; the boundaries between each phase are often fluid and subjective with
subtle differences. For more details, see Giblin et al (2021) and the appendix on project stages.

11

See Bank of Thailand and Hong Kong Monetary Authority (2020) and BIS Innovation Hub et al (2021a) for
the detailed central bank journeys and project overview of Phases 1 and 2.

12

This distinguishes mBridge from other multi-CBDC projects, in which the underlying technology was built
by non-central bank entities.

9

Project mBridge: Connecting economies through CBDC

BIS Innovation Hub and of the New York Innovation Centre at the Federal Reserve
Bank of New York.

4. Cross-border payments

4.1 The state of cross-border payments
Recent decades have witnessed rapid growth in global economic integration. At the
same time, the system of cross-border financial flows underpinning this integration
has not kept pace.13 Cross-border payments are typically made through a global
network of correspondent banks involving multiple intermediaries that are
fragmented across different time zones and operating hours. In addition, the current
corresponding banking network has yet to cover some less developed markets.
While correspondent banks play a critical role in cross-border payments, due to
duplicated processes and steps in the correspondent banking chain, cross-border
payments exhibit high costs, low speed, operational complexities, limited access and
low transparency. These inefficiencies also introduce settlement risk into the system,
to the detriment of both financial intermediaries and end users.
Moreover, the bulk of settlement in correspondent banking occurs in
commercial bank credit, representing a liability of the commercial bank. As such, it
carries the associated credit and liquidity risks where settlement funds may not be
available in the event of illiquidity or insolvency. Although the foregoing risk rarely
materialises, it becomes significant when aggregated over large values and long
settlement periods. Settlement in central bank money, the safest settlement asset,
eliminates this risk; however, it is typically restricted to interbank domestic payments
on access-controlled central bank real-time gross settlement (RTGS) systems.14 One
exception is Continuous Linked Settlement (CLS), a specialist institution that settles
FX transactions on a PvP basis and maintains an account at each of the central banks
whose currencies it settles; however, to date only a limited number of currencies are
supported.15 The costs associated with the correspondent banking model are
substantial – private sector estimates suggest that, in 2020, for nearly $23.5 trillion in
cross-border transactions flows, transaction charges amounted to around 0.5%, or
approximately $120 billion (excluding FX costs),16 roughly equivalent to the nominal
GDP of Morocco. Furthermore, adverse secondary effects not captured in this figure,
such as settlement delays and risks, likely amount to far greater costs.

13

Innovation in the payments space has been concentrated mostly in the domestic arena, with cross-border
payments often left on the sidelines. While incumbent payment providers and private sector players have
pursued various initiatives to alleviate longstanding challenges in international payments (SWIFT global
payments innovation, Visa business to business connect and continuous linked settlement system are some
examples), they are limited in scope and high operational costs persist.

14

See Casu and Wandhofer (2017), Board of Governors of the Federal Reserve System (2022) and Bech et al
(2020).

15

See CPMI (2012) and Bank of International Settlements, BIS Quarterly Review, December 2019.

16

See Oliver Wyman and JP Morgan (2021).

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Project mBridge: Connecting economies through CBDC

This traditional model of cross-border payments presents even more
challenges for emerging market and developing economies (EMDEs). Banks started
paring back their correspondent networks and services after the Great Financial
Crisis, with smaller economies likely experiencing a greater decline, leaving many
without sufficient or affordable access to the global financial system.17 Furthermore,
cross-border transactions are often settled in a handful of dominant currencies and
FX trading involving non-dominant currency pairs remains limited.18 This exposes
EMDEs to spillover effects from the monetary policies of jurisdictions from which the
foreign currency originates, as well as associated financial stability risks, such as
credit cycles. The limited international role of many local EMDE currencies also raises
the issue of access to liquidity for these economies in times of global financial
turbulence.19
FX settlement risk has also risen in recent years on the back of a declining
share of global settlements using PvP mechanisms, owing in part to the fact that
existing arrangements such as CLS do not support many EMDE currencies in which
trading volumes have increased substantially (Graph 2).20 By providing a shared
platform on which participants can conduct peer-to-peer payments directly in the
safety of the CBDCs of multiple jurisdictions, mBridge has the potential to alleviate
many of the aforementioned challenges in international payments, extend PvP
protection to currencies beyond those covered by existing systems and support the
use of local currencies in cross-border settlement.
FX settlement risk: increasing and global
FX settlement methods1

Proportion of settlements with PvP

Graph 2
CLS-ineligible currency pairs

protection2

1

“PvP settlement” includes CLS and settlement through systems such as Hong Kong’s CHATS. 2 The median value is represented by a horizontal
line, with 50% of the values falling in the range shown in the box. The highest and lowest values are represented by the upper and lower end points
of the vertical lines.
Source: Bech and Holden (2019).

17

See Rice et al (2020).

18

See Bank for International Settlements, https://www.bis.org/statistics/rpfx19_fx.pdf.

19

See Asian Development Bank (2021).

20

See Bech and Holden (2019) and CPMI (2022).

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Project mBridge: Connecting economies through CBDC

4.2 International trade as mBridge’s first business use case
Prior to the pilot, the project team engaged extensively with the private sector to
identify business use cases for the platform. Private sector participants comprising
financial institutions, banking associations and exchanges from all four participating
jurisdictions identified 15 potential cross-border use cases in which mBridge could
provide significant value. These included diverse areas of opportunity such as
international trade settlement, remittances, tokenised bond issuance, e-commerce
and more.21 International trade settlement was chosen as the first business use case
to be piloted on mBridge given the sheer size of trade value in the four participating
jurisdictions and the importance of trade to the region (Box A).22 By supporting the
development of local FX markets, extending the safety of central bank money to
international settlements and alleviating many of the aforementioned pain points of
cross-border payments, mBridge has the potential to facilitate trade in the region
and, in turn, support trade-driven economic growth.

21

See BISIH et al (2021c).

22

While this phase of the project seeks to concretely demonstrate international trade settlement, mBridge
holds the promise of an array of additional functionalities to be explored in future phases.

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Project mBridge: Connecting economies through CBDC

Box A

Regional trade
Intragroup trade between Mainland China, Hong Kong SAR, Thailand and the UAE
amounted to US$563.6 billion in 2021, with important trading relationships between
each of the four jurisdictions (Graph 3). Trade also plays a crucial role in each
jurisdiction; for example, merchandise exports represented 18%, 46%, 93% and
159% of GDP in 2020 for Mainland China, Thailand, the UAE and Hong Kong SAR,
respectively, according to World Bank data.23 Including top players in global supply
chains and commodity markets, these four jurisdictions are also important trading
partners to the rest of the world. Together, they accounted for around US$8.7 trillion
of merchandise trade in 2021, representing 19% of all such trade worldwide,
according to World Bank data. As such, mBridge has the potential to support
significant global trade flows as more jurisdictions join the platform.
Trade in the region continues to be settled predominantly in foreign
currencies, despite the deepening intra-regional economic ties and supply chain
integration over recent decades. Local currencies play limited roles in international
trade, owing in part to the relatively high transaction costs associated with most
Asian currencies compared with those of major currencies.24 This dependence on
foreign currencies for cross-border payments could inadvertently impact monetary
sovereignty through monetary policy spillovers from the currency-originating
jurisdiction, and adds more intermediaries and steps to the overall process. For
example, a payment between a Thai corporate (the payer) importing goods from a
Mainland Chinese corporate (the payee) using a foreign currency as the invoicing
currency would involve the Thai payer’s local bank, the Mainland Chinese payee’s
local bank, and the payer and payee’s correspondent banks (Graph 4). Additional
complexities are involved if the Thai and Mainland Chinese corporates’ banks are
small, local banks with no direct correspondent network, in which case even more
intermediaries and steps are required.25 With multiple banks along the payment
chain, transaction fees can be charged and know your customer (KYC)/anti-money
laundering (AML)/counter-terrorist financing (CTF) checks can be undertaken at
each bank, and numerous break points can arise.26

23

See World Bank Open Data, https://data.worldbank.org/.

24

See Shimizu (2019).

25

See Oliver Wyman and JP Morgan (2021).

26

See Casu and Wandhofer (2017).

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Project mBridge: Connecting economies through CBDC

2021 intra-group trade among the four jurisdictions (in US$ billions)

Typical correspondent banking payments process

14

Graph 3

Graph 4

Project mBridge: Connecting economies through CBDC

5. Pilot
The mBridge pilot27 moves the needle in the multi-CBDC space in terms of the
nature of transactions, the number and value of transactions and the number of
participants. Over the course of six weeks, Project mBridge conducted a large-scale
pilot settling real-value transactions in CBDC from each of the four participating
jurisdictions directly on the mBridge ledger. It represented the largest cross-border
CBDC pilot to date, with over US$ 12 million of CBDCs issued onto the platform,
over US$ 22 million of payments and FX PvP instantly settled across borders, and the
greatest number of direct pilot participants. Twenty of the region’s largest
commercial banks participated in the pilot (Graph 5), settling real value on behalf of
their corporate clients, focusing primarily on settlement for international trade as
well as between interbank groups. Where the pilot differs from other multi-CBDC
projects is in the final settlement of real-value transactions directly on the platform
(as opposed to on the domestic payment systems) and the fact that it included
paying and receiving banks conducting transactions directly on behalf corporate
clients (as opposed to interbank transfers). By providing a shared platform on which
participants conducted peer-to-peer payments directly in the safety of central bank
money across multiple jurisdictions, the pilot successfully demonstrated the
platform’s ability to improve cross-border payment speed and efficiency, and to
reduce settlement risks in a real-world setting.
Participating commercial banks in the pilot

27

Graph 5

For more details on what constitutes a pilot, see Giblin et al (2021). See also the appendix on project stages.

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Project mBridge: Connecting economies through CBDC

5.1 Preparation and setup
The mBridge pilot required extensive coordination and engagement both within and
among central banks and commercial banks to be successfully completed. First, as
CBDC represented a new digital form of central bank money in many of the
participating jurisdictions, significant interdepartmental coordination across
Payment, Legal, Risk, Financial Stability, Monetary Policy and Treasury teams (among
others) took place within each central bank and each commercial bank to facilitate
both the availability of CBDC (from a central bank perspective) and the ability to
transact in CBDC (from a commercial bank perspective) over the course of the pilot.
Second, due to the cross-border nature of transactions, extensive cross-jurisdictional
synchronisation also took place among the four central banks and 20 commercial
banks to ensure the appropriate operational and legal jurisdictional requirements
were met. For example, central banks needed to ensure sufficient liquidity was
available in the local currency for transactions between each jurisdiction pair, while
commercial banks needed to coordinate among each other, as well as with their
corporate clients, which transactions to route through the platform.
To provide the legal certainty needed to conduct a real-value pilot, three
important legal documents tailored for the pilot were drafted and executed by the
participants:28
i)

Pilot participation agreement: outlined central banks’ role and
provision of services under the pilot scheme along with the rights and
responsibilities of the commercial bank participants.

ii)

Platform operating terms: provided overarching principles and
procedures for commercial banks on the use of mBridge; notably, it
included the circumstances under which CBDC payments and exchanges
on the platform are deemed made, completed, irrevocable and final,
achieving legal certainty for settlement finality on the platform.

iii)

Terms and conditions: outlined currency-specific rules governing the
use of local CBDCs by foreign commercial banks; for example, it outlined
the terms of use of the CBDCs and rights of holders of the CBDCs on
mBridge. The terms and conditions were embedded as a clickthrough
agreement on the platform.

To simplify the technical operation of the platform for the purposes of the
pilot, the mBridge ledger was deployed and operated in a high-security, centralised
cloud based in Hong Kong SAR. This enabled participants to access the platform as
a software as a service (SaaS) offering though a convenient front-end, web-based
user interface (UI). In future pilot phases, however, the project team will explore
further distributing the deployment and operations of the platform among the

28

16

In certain jurisdictions, additional documents were drafted on top of these three documents, such as a
business continuity plan.

Project mBridge: Connecting economies through CBDC

participants for data privacy and governance reasons (see subsection 7.1.3 for more
details).
With all the necessary groundwork laid, the pilot then took place over a
period of six weeks between 15 August and 23 September 2022. It was conducted in
three consecutive phases, detailed in Graph 6, with each phase increasing the
number of jurisdictions involved. The first phase included only transactions between
banks in Hong Kong SAR and Mainland China. The second phase saw the addition of
UAE banks, and the final phase included Thai banks. A series of “dress rehearsals”
also took place in a parallel user acceptance testing (UAT) environment prior to the
start of each phase, to get banks acquainted with the platform and ensure smooth
operations.
Pilot timeline

Graph 6

5.2 Transaction types and functional requirements
Transaction types that feature prominently in the context of international trade and
that facilitate cross-border settlement in local currency were explored in the pilot.
More specifically, the pilot tested the following three transaction types (Graph 7):29,30
i.

Issuance and redemption of CBDC between central banks and their domestic
commercial banks.

ii.

Cross-border payment between commercial banks in local CBDC (for
example, a UAE corporate paying a mainland Chinese corporate in e-CNY
through their commercial banks participating on the platform).

29

Since the pilot was conducted between more than two jurisdictions, other transaction permutations were
possible, such as cross-border transactions denominated in a third-jurisdiction currency. For the pilot, these
additional transaction types were considered out of scope (see subsection 7.1.2 for more details).

30

For the purpose of this report, all references to e-CNY, e-THB, e-AED and e-HKD refer to the wholesale use
of CBDC of each currency.

17

Project mBridge: Connecting economies through CBDC

iii.

Cross-border PvP FX between commercial banks in local CBDC (for example,
a Thai bank exchanging e-THB for e-HKD with a Hong Kong SAR bank on
the platform)

Transaction types tested on the platform

Graph 7

These three transaction types are underpinned by the core functionality of
the platform, which is split between the two primary participant types – central
banks and commercial banks.
A central bank participant has the widest set of functions on the platform.
Central banks are the exclusive issuers and redeemers of CBDC on mBridge,
effectively providing fungibility between M0 reserves and CBDC through RTGS onand off-ramps to the platform or automatic connectivity to domestic CBDC systems.
They also have the sole authority to onboard and offboard their domestic
commercial banks and set parameters for what currencies their banks can hold, how
much they can hold of each currency and what currency pairs they can conduct FX
PvP with. Additionally, central banks can view the necessary transaction information
of their domestic banks, and foreign banks using their domestic CBDC, to meet
supervisory needs without compromising data privacy (see subsection 6.4 for more
details).
Meanwhile, commercial banks have a more limited set of functionalities.
They can request issuance and redemption of CBDCs on the platform from their
domestic central bank in exchange for a debit or credit of their reserve accounts or
equivalent accounts in their domestic CBDC systems.31 They can also initiate peerto-peer push payments in any currency on the platform with any commercial-bank

31

18

See more on manual and automatic issuance and redemption in Section 6.

Project mBridge: Connecting economies through CBDC

counterparty on the platform.32 Furthermore, commercial banks can initiate PvP
transactions or respond to similar transactions initiated by another commercial bank
to conduct atomic FX transactions in local currency pairs. Lastly, each participating
commercial bank can query the platform to view their past transactions and current
holdings on-bridge.
The platform will also strive to facilitate non-functional requirements that
are in many ways prerequisites to their functional counterparts. These include, but
are not limited to, data integrity, transaction privacy, platform scalability, transaction
throughput and transparent system monitoring. These attributes are all essential
components of a well-functioning platform and often present optimisation
challenges during implementation. For example, security, scalability and
decentralisation lead to implementation tradeoffs that need to be carefully
evaluated.33 More on how some of these features are supported can be found in
Section 6.

5.3 Pilot statistics
Table 1 presents pilot transaction statistics. Over the course of six weeks, HK$ 8.5
million in e-HKD, ¥11.8 million in e-CNY, 31‫إ‬.‫ د‬million in e-AED and ฿32.1 million in
e-THB were issued onto mBridge as M0 central-bank-issued CBDC. Across all four
currencies, issuance amounted to US$ 12.1 million of liquidity on the platform. This,
in turn, facilitated 164 cross-border payment and FX PvP transactions totalling
US$ 22.1 million, suggesting that the CBDCs issued on mBridge during the pilot
facilitated nearly double the amount in cross-border value.
Breaking down payment and FX PvP values transacted on the platform by
currency, HK$13.2 million was in e-HKD, ¥23.6 million in e-CNY, 60.1‫إ‬.‫ د‬million in eAED and ฿23.5 million in e-THB. Payment and FX PvP transactions were mostly
comprised of underlying corporate payments for the international settlement of
goods and services. Furthermore, a number of interbank transactions also took
place, paving the way for additional use cases to be settled on mBridge.
As can be seen from Table 1, there are asymmetries across the four CBDCs
both in terms of the number of transactions and their value, which reflect several
factors. While the pilot consisted of real-value corporate transactions, it was also
conducted in an orchestrated manner with the setup having implications for the
activity of each CBDC. For example, as Hong Kong SAR and Mainland Chinese banks
were the only commercial bank participants to start transacting in the first phase of
the pilot, e-HKD and e-CNY were available on the platform for the full duration of
the six weeks. On the other hand, e-AED was only available starting in Phase 2 when
UAE banks joined the pilot, followed by e-THB starting in Phase 3 when Thai banks
joined. This explains why e-HKD and e-CNY transactions greatly outnumbered those
of e-AED and e-THB. Furthermore, differences in transaction values reflect different

32

While it is technically feasible to initiate push payments in any participating currency on the platform, only
transaction types involving a currency that is local to one of the counterparties was tested in the pilot, as
explained earlier in the subsection.

33

See Hafid et al (2020).

19

Project mBridge: Connecting economies through CBDC

rules and considerations set by the issuing central banks. For example, transaction
values in e-AED were significantly higher relative to the other three currencies,
owing in part to the fact that all e-AED-denominated transactions were interbank
rather than corporate payments, and reflecting the scale and materiality of interbank
transactions that typically occur between the UAE and the other three jurisdictions.
Subsection 7.1 provides a more detailed discussion on why these different rules and
restrictions were put in place.
Pilot transaction statistics
Number of transactions

Table 1
e-HKD

e-CNY

e-AED

e-THB

Total

Issuance

17

35

10

8

70

Payment and FX PvP

51

72

23

18

164

Of which payment

40

69

15

8

132

Of which FX PvP

11

3

8

10

32

Redemption

18

35

10

8

71

Total

86

142

43

34

305

e-HKD

e-CNY

e-AED

e-THB

Total (US$)

Issuance

8,483,655

11,821,780

31,024,625

32,113,000

12,118,083

Payment and FX PvP

13,194,963

23,643,559

60,058,250

23,481,840

22,094,936

Of which payment

10,279,078

23,479,504

60,039,250

10,830,920

21,347,208

Of which FX PvP

2,915,885

164,055

19,000

12,650,920

747,728

Redemption

8,483,655

11,821,780

31,024,625

32,113,000

12,118,083

Total

30,162,272

47,287,119

122,107,500

87,707,840

46,331,101

Transaction value (local
currency)

Transaction values in each currency are denominated in local currency, while transaction values in the “Total” column were converted to
US dollars using average daily exchange rates between 15 August and 23 September 2022 taken from Bloomberg.

On the platform, a commercial bank can transact with any other
commercial bank directly in a peer-to-peer manner. Among the 20 participating
commercial banks, five from each jurisdiction, this connectivity enabled 150 different
bilateral and direct potential connections.34 Over the six weeks of the pilot, 41
unique, cross-border, peer-to-peer linkages were enacted, with each bank
transacting on average with two banks in other jurisdictions in a currency that is
local to at least one of the counterparties (Graph 8). This bilateral connectivity
enabled by mBridge contrasts with payments routed through the correspondent

34

20

Each of the 20 banks can connect to 15 banks in the other three jurisdictions; we then divide the
multiplicative value of 300 (20×15) by two to not count each connection twice.

Project mBridge: Connecting economies through CBDC

banking model, in which banks do not typically have the direct connections required
to transmit cross-border payments across currencies and therefore require chains of
linked correspondent institutions and routing through third-party currencies, adding
time, friction and settlement risk. The peer-to-peer linkages between payee and
payer banks offered by mBridge can significantly reduce the complexity of crossborder payments, and as such, tackle many of the associated pain points. Moreover,
settlement on mBridge occurs in the safety of central bank money, reducing or even
eliminating a key risk in correspondent banking payments.35
Pilot transaction linkages

Graph 8

Visual representation of the 41 unique, cross-border, peer-to-peer linkages enacted over the course of the pilot. Each
unique linkage can involve two currencies – those local to the transacting counterparties. Colours of the arrows in the
graph represent the currency of the jurisdiction in each corner with the same colour.

35

mBridge also demonstrates the potential to settle transactions instantly, therefore reducing settlement risk
compared with the correspondent banking model, in which there is currently a three- to five-day delay
between payment and settlement for a typical cross-border transaction processed via correspondent
banks. See BISIH et al (2021a) for details.

21

Project mBridge: Connecting economies through CBDC

5.4 Key lessons
The pilot’s real-world setting provided numerous lessons that will inform the
development of future phases of the project. Platform design decisions, constraints
imposed by incumbent systems and participant relationship dynamics all influenced
how the platform was used, and consequentially will have an impact on shaping the
roadmap.
One important observation is the limited number of FX PvP transactions
which were conducted during the pilot compared with one-way payments (see Table
1). This reflected in part the relatively short window of time banks had to off-load
their foreign CBDCs due to the requirement set by some central banks to clear
balances of their CBDCs at the end of the day, along with the limited overlapping
RTGS hours between the four jurisdictions. FX rates were also determined off-bridge
before FX PvP transactions took place on the platform, and thus the lack of an
efficient FX price-discovery mechanism on-bridge added time and complexity to the
workflow. As a result, many banks relied on requesting foreign currency against preexisting balances in nostro accounts, instead of making use of the FX PvP function
on mBridge.36 Given the need to rely on existing correspondent banking
relationships for liquidity, the real-value nature of transactions and the short time
span of the pilot, transactions took place, for the most part, between banks with
pre-existing business and service relationships. To fully benefit from the direct
bilateral connectivity offered by mBridge and its FX PvP functionality, it is therefore
important that liquidity provision and management functions, along with measures
to facilitate FX dealing on-bridge, are appropriately integrated into the platform in
the future.
Finally, an additional finding from the pilot was that the ease with which
mBridge integrates with domestic wholesale payment systems can save time for
participants and allow for straight-through processing. The modular framework of
the platform allowed for both manual and automatic integration with domestic
payment systems. It is likely no coincidence that, with the PBC integrating the
platform into their live e-CNY domestic system using the automatic issuance and
redemption features, issuance and redemption transactions were highest in e-CNY.37
With the intention to move towards automatic integration in the future, the other
central banks in the interim made use of the manual issuance and redemption
function on mBridge. The manual process added time and friction to the processes,
although any control and coordination issues were quickly resolved during the pilot.
Seamless integration by central banks of the platform with domestic CBDC and
payment infrastructures and automation of the CBDC issuance and redemption
processes are therefore crucial for the future success of mBridge.

36

For example, while ICBC (Thailand) was not a pilot participant, as the CNY clearing bank in Thailand, they
provided e-CNY liquidity assistance to the Thai commercial banks participating in the pilot. Through their
access to ICBC Head Office in Mainland China, ICBC (Thailand) was able to assist Thai banks in converting
e-CNY on and off mBridge.

37

That being said, the relatively high number of e-CNY issuances and redemptions could also reflect greater
demand for e-CNY-denominated transactions given the relatively high share of regional trade accounted
for by Mainland China.

22

Project mBridge: Connecting economies through CBDC

5.5 Participant feedback
Upon completion of the pilot, participating commercial banks from each jurisdiction
were asked to provide their feedback through a structured questionnaire covering
the functional features of the platform, business use cases, compliance and legal
considerations, platform operations and input on the future directions of Project
mBridge. In general, most respondents found the platform intuitive and easy to use.
They found taking part in the pilot useful in understanding how a CBDC platform
can integrate into their workflow and all expressed interest in participating in future
pilots. The majority of respondents acknowledged the benefits of switching from
existing cross-border payment frameworks to the mBridge platform in terms of
speed, intermediary reduction, transparency, cost, availability and risk reduction, as
well as the excellent potential of the platform in its current form to be developed
into a production-ready system.
Post-pilot commercial bank feedback
Feedback included:


Platform was intuitive and easy to use
Taking part in the pilot was useful in
understanding how a CBDC platform
can integrate into commercial bank
workflows
Interest in taking part in future
mBridge pilots
Benefits of using mBridge compared
with existing systems in terms of
speed, transparency, cost, availability
and risk reduction

Table 2
Suggestions for improvement included:




Introducing FX market
makers/liquidity providers to
facilitate FX dealing on-bridge
Interoperability with domestic
systems and API connectivity to
enable end-to-end execution and
straight through processing
Maker-checker mechanisms
More jurisdictions and currencies
More use cases
More comprehensive set of terms and
conditions and overarching legal and
governance structure as platform
moves towards production

Respondents also provided valuable insight into areas in which mBridge
features can be enhanced or added to for banks to be able to use the platform at
scale and to avoid putting undue pressure and risk on their operations. These
included, for example, liquidity management tools, interoperability with domestic
systems and application programming interface (API) connectivity, and transaction
reporting/statements, among other UI improvements. Respondents also welcomed
the idea of testing more use cases and adding more jurisdictions and currencies to
the platform. Finally, banks noted the need for a more comprehensive set of terms
and conditions, and overarching legal and governance structure, as the platform
moves towards production stage. A detailed list of feedback is outlined in Table 2.
These suggestions are instrumental in shaping the future roadmap for mBridge (see
Section 8 for more details).

23

Project mBridge: Connecting economies through CBDC

6. Technical platform design
Central bank money is the safest form of money in any currency area and plays a
fundamental role in the financial system and overall economy.38 It is therefore
natural for a CBDC platform to be designed and built by central banks, for central
banks. After experimenting with different technology architectures in earlier phases,
the project team developed a new native blockchain for mBridge, the mBridge
ledger (mBL), to meet the needs of the central bank and commercial participants.
Under the Steering Committee structure, platform requirements are first discussed
by subcommittees chaired by the four central banks before being implemented by
the development team. The code is open and available to all central bank project
members for input and review.
The mBL aims to serve as a specialised, flexible and scalable
implementation for multi-currency cross-border payments. To maximise the
accessibility, adaptability and extendibility of the platform for current and future
users, the platform implements a modular design that provides users and
developers with a familiar service-oriented architecture. In this approach, different
modules such as payment, foreign exchange, capital management and compliance
are decoupled and modularised to accommodate the evolving needs from different
jurisdictions. This allows participating central banks to validate, adapt and extend
functionality according to their technical, business and regulatory requirements, and
aims to support each jurisdiction’s autonomy in implementation and adoption of the
platform.

6.1 Network topology
At the core of the mBL are the central banks, who each run a validating node that
operates the mBL consensus protocol. As shown in Graph 9, central bank validating
nodes form a complete, connected graph with a link between every pair of nodes.39
Each central bank can onboard its domestic commercial banks onto the platform,
and the commercial banks of each jurisdiction are all connected to the onboarding
central bank and hence to the validating core of the mBL. Once onboarded,
commercial banks can transact on behalf of their clients, extending the reach of the
platform.

38

See Carstens (2021).

39

In the mathematical field of graph theory, a complete graph is a simple, undirected graph in which every
pair of distinct vertices is connected by a unique edge. See Bang-Jensen and Gutin (2018).

24

Project mBridge: Connecting economies through CBDC

High-level network topology

Graph 9

6.2 Functional architecture
As shown in Graph 10, the mBridge platform can be broken down into the following
five distinct layers, with each layer encapsulating multiple functional modules:
1.

Access layer: supports different ways to access the platform. For the pilot, a
web-based front-end was developed that enabled pilot participants to directly
use the platform through a web browser without requiring technical
integrations. This layer also supports an API module, against which participants
can directly integrate with their core banking payment systems. Lastly, a
gateway module provides request authentication controls and load balancing.

2.

Application layer: includes a wide range of local back-end services. Wallet
management provides encryption and decryption services based on self-hosted
private keys, while privacy protection provides local key generation and
management services for the pseudo-anonymous key pairs. The transaction
engine executes business logic on the underlying blockchain and data layers.

25

Project mBridge: Connecting economies through CBDC

Meanwhile, compliance management enforces controls such as value limits and
currency types, and participant management offers access management and
supervisory functions for the central banks. Finally, the scanning module is
responsible for the monitoring and parsing of on-chain data, while the
authentication module authenticates actions against the underlying blockchain
and data layers.
3.

Data layer: encapsulates local data storage and supports relational databases
and file storage functions.

4.

Blockchain layer: as the core of the platform, it consists of smart contracts and
consensus protocols and enables the technical settlement of all transactions. It
also includes a key-value database (KV database) to store data that is essential
to the operations of mBridge. For details on the blockchain API interface, see
the appendix on technical design.

5.

Basic service layer: as the lowest level of the technical stack (see the appendix
on technical design for more details), this layer provides the necessary software
and hardware facilities for the system, such as data transmission protocols, CPU
virtualisation, network resources and server hardware.

mBridge platform layers

Graph 10

6.3 Consensus protocol
At the heart of the mBridge platform is a private,40 permissioned41 distributed
system. Validating the ledger is the process of accepting or rejecting proposed

40

Private refers to the fact that a participant needs to be onboarded by a representative central bank on to
the ledger in order to participate.

41

Permissioned refers to the fact that validation of the ledger is reserved to permissioned entities, ie the
central banks.

26

Project mBridge: Connecting economies through CBDC

transactions to the ledger and is done through the consensus mechanism which lies
at the core of any DLT platform.42 There are many types of consensus mechanism,
the most familiar of which are proof-of-work and proof-of-stake used in the public,
permissionless Bitcoin and Ethereum ledgers, respectively. The trade-offs and
economic incentives in private, permissioned ledgers, however, are different from
those in public, permissionless ones, as private, permissioned ledgers do not need to
provide economic incentives for public validators. One desirable property of
consensus mechanisms is Byzantine fault tolerance (BFT),43 or resilience to
malfunctioning components that provide conflicting information to different parts of
the system.
The mBL uses a consensus mechanism named HotStuff+, which is a
variation of HotStuff first introduced in Yin et al (2019). HotStuff has numerous
desirable properties, notably that its runtime, a measure of the computational
complexity of an algorithm, scales linearly with respect to the number of validating
nodes. This contrasts with most other BFT and practical-BFT protocols that are
quadratic with respect to the number of validators and therefore require greater
runtime for the same number of validating nodes.44
For future consideration, a new consensus mechanism named Dashing is
being tested by the development team. Dashing is a dynamic-threshold blockchain
consensus protocol for permissioned blockchain, and achieves higher efficiency and
robustness than HotStuff+ does. It uses triple certificate security, a process in which
three certificates with different thresholds are used under different network
circumstances. As a result, both higher efficiency and robustness can be achieved.
Additionally, a decoupling of block proposals from the consensus achieves greater
scalability under a high concurrency of transactions.45

6.4 Privacy controls
When designing CBDC platforms, choices concerning privacy are often top of mind
for policymakers. Design choices should be considered in terms of privacy of what
and from whom. It is also important to keep in mind that privacy is not a binary
choice between anonymity and full disclosure, and there are many subtleties
involved. For example, in the case of cash transactions, only the counterparties to
the transaction know of its existence, while the issuer of the currency does not.
However, if the cash transaction was large and for the purpose of a real estate title

42

This can be generalised as the problem of State Machine Replication, a method for implementing a faulttolerant service coordinating user interactions over a set of replicated servers. See Lamport (1978).

43

See Lamport et al (1982).

44

The HotStuff consensus algorithm can be broken down into four distinct phases – prepare, pre-commit,
commit and decide – which are executed sequentially in the original HotStuff implementation. HotStuff+
adds an asynchronous implementation to the validation process and supports dynamic switching and
adding validator nodes; as a result, it increases the performance and resilience.

45

See Duan et al (2022).

27

Project mBridge: Connecting economies through CBDC

transfer, the recipient would likely require some degree of disclosure on the origin
of the funds.
The mBridge platform implements privacy controls for core transaction
data, which comprise payer and payee identities, the amount transacted and the
details of the CBDC invoked. Through an implementation of pseudo-anonymous
addresses using randomly generated self-issued key pairs – the flow of which is
detailed in the appendix on technical design – the mBridge platform ensures that
sensitive transaction details can only be viewed by the counterparties of the
transaction, their respective central banks and the currency issuer. For example,
consider a hypothetical scenario in which a UAE commercial bank makes a payment
to a Hong Kong SAR commercial bank in e-HKD on mBridge; the details of the
transaction would only be visible to the payer, the recipient, the CBUAE and the
HKMA, while the BOT and the PBCDCI and other participants would not be able to
see any sensitive transaction information (Graph 11). If, instead, the payment was in
e-THB (note this transaction type was not within the scope of the pilot and is used
purely for illustrative purposes), the BOT would also be able to see the transaction
details. Without these controls in place, sensitive transaction details would be visible
to any participant with access to the ledger, which in the case of mBridge is every
participant on the platform.
mBridge privacy controls

28

Graph 11

Project mBridge: Connecting economies through CBDC

6.5 Functional implementations
6.5.1 Issuance and redemption
Recognising that some jurisdictions may not yet have a CBDC system, and that API
integration takes time, the platform supports a manual mode of integration in
addition to an automated one. This supports interoperability and coexistence with
domestic payment systems, as both CBDC and traditional payment systems can be
easily connected to the platform. Nevertheless, a key lesson from the pilot (as
described in subsection 5.4) is that as the platform moves closer to the production
stage, automated integration with the standing systems of the participating central
banks is important to reap the full benefits of mBridge. Specifically, the mBridge
ledger enables two issuance and redemption models, manual and automatic, as
shown in Graph 12.
1.

Manual issuance and redemption: under this model, central banks can issue
and redeem their CBDCs on mBridge without needing to modify their existing
payment arrangements. A commercial bank first submits an issuance request
and conducts a manual off-bridge transfer of funds to the issuing central bank
through the domestic payment system, which can be either a traditional
payment system such as RTGS or a domestic CBDC system. Upon receipt of the
funds and the completion of internal control checks, the central bank issues the
equivalent amount of CBDC into the commercial bank’s wallet on mBridge.
Similarly, redemption is triggered by a commercial bank’s request with the
amount of CBDC to be redeemed being sent to the central bank on mBridge.
The central bank then manually transfers the equivalent amount of funds to the
commercial bank through the domestic payment system and completes the
redemption transaction.

2.

Automatic issuance and redemption: this model directly integrates the
domestic payment system and/or CBDC network with the mBridge platform,
allowing transactions between the two systems to be processed in a highly
automated manner. The process involves a commercial bank sending money
though the local payment system to a designated account/wallet which would
then automatically trigger a CBDC issuance on mBridge. Similarly, a commercial
bank initiating a redemption on mBridge would automatically trigger a
payment to the commercial bank’s account/wallet.

29

Project mBridge: Connecting economies through CBDC

mBridge issuance and redemption
A. Manual issuance and redemption

Graph 12
B. Automatic issuance and redemption

6.5.2 Payment and PvP
There are two types of payment that can be performed on mBridge (see the
appendix on technical design for a more detailed flow):
1.

Simple one-currency push payments: starts with the initiator selecting the
currency, amount and counterparty. The initiator then conducts the appropriate
off-bridge compliance checks, including AML/CTF/sanctions checks, and sends
a payment request to the payee. Once the payee receives this request, it
conducts its own off-bridge compliance check and, if appropriate, confirms the
payment. Once received, the initiator will call the payment interface which
invokes the contract to pay the specified currency amount to the receiving
address.

2.

Dual-currency FX PvP transactions: these transactions are atomic, meaning
they are indivisible – either both legs of the transaction settle or neither settle.
A PvP transaction involves three distinct phases: initiation, commit and execute.
In the first phase, the initiator selects the currency pair, amount, FX rate (which
is determined off-bridge) and a counterparty. Then, like a one-way payment,
the initiator conducts the appropriate off-bridge compliance checks before
sending a payment request to the counterparty. Once the counterparty
confirms, the commitment phase will begin during which the first leg of the
transaction is committed; the PvP contract then waits for the other transaction
to be triggered and emits an event to the counterparty that the initiator is ready
to make payment. Finally, in the execution phase, the counterpart commits the
other leg of the transaction, triggering the atomic execution of the PvP
contract.

30

Project mBridge: Connecting economies through CBDC

7. Policy, legal and regulatory considerations

7.1 Policy considerations
A multi-CBDC common platform raises several policy, legal and regulatory
considerations. The rich diversity of monetary systems and governance frameworks
of the four participating jurisdictions enabled the development team to explore a
platform design that can accommodate jurisdiction-specific nuances and maximise
policy flexibility for individual jurisdictions, while at the same time adhere to a
common set of principles that are critical for the functioning of the platform.
Meanwhile, the pilot’s real-world setting shone light on a range of policy and legal
issues that need to be further explored on the path to a production-ready system.

7.1.1 Measures to preserve monetary sovereignty
Without the appropriate safeguards, cross-border use of CBDCs and broadening
direct access to central bank money could hamper central banks’ ability to maintain
monetary and financial stability. For example, as the accessibility of domestic
institutions to foreign currencies and of foreign institutions to domestic currency
increases, heightened offshore demand for CBDCs can drive volatile capital flows,
balances of domestic money offshore and substitution away from the domestic
currency.46 In designing a multi-CBDC platform, a key question for central banks to
consider is whether commercial bank participants can access the CBDCs of
jurisdictions where they are not themselves locally domiciled and regulated. If so,
this broadens direct access to central bank money to foreign banks as compared
with today’s systems, in which access is often conditional on local supervision or
licensing.47,48
On mBridge, both domestic and foreign commercial banks are permitted
to directly hold and transact in CBDC, since this is a desirable condition to ensure
seamless cross-border payments in central bank money. The platform’s design
follows the CBDC principle of “do no harm” – designing CBDC ecosystems that
support public policy objectives and do not impede central banks’ ability to carry
out their mandates.49 To ensure that mBridge fully respects the monetary
sovereignty and policies of each participating central bank, it aims to provide central
banks with the tools needed to allow this foreign access without compromising
control of their currency. It does this through flexible control functions over CBDC
issuance and redemption, transaction currencies and amounts, and visibility into
usage. These controls can also be further customised to accommodate the evolving
management needs of the jurisdiction.

46

See IMF (2020) and CPMI (2018).

47

See BISIH (2022).

48

A related question concerning access policy is whether to accept non-bank participants as account holders,
but this is out of the scope of the current phase of the project.

49

See BIS et al (2022).

31

Project mBridge: Connecting economies through CBDC

While CBDCs can be held and used by foreign commercial banks, only
domestic banks can be issued or redeem CBDC against reserve balances. This
ensures that no changes are made to the monetary base through the exchange of
reserves to CBDC. Measures limiting the circulation of CBDCs offshore, such as
restrictions on which offshore entities can hold a central bank’s CBDC and limits on
amounts held, can also serve as useful tools to allow central banks to broaden
access without compromising monetary sovereignty.50 Central banks can also tailor
the time frames during which their CBDCs are allowed to exist on the platform. For
example, CBDCs can be restricted to intraday circulation, leaving no effects on the
central bank’s overnight balance sheet, or be permitted to be held overnight, with
impacts on the balance sheet. Other arbitrary time periods (eg week-end or
month-end) can also be set, giving central banks the tools to intervene periodically
for other policy or supervisory purposes.51
As mBridge is still moving towards a production stage, most of the controls
discussed above were implemented manually by each central bank during the pilot.
Future phases will explore further integration of these controls into the technical
platform. For example, CBDC smart contracts can be used to clear balances through
an automated sweep at specified time intervals, and access and value controls can
be automated depending on the jurisdiction of the user, demonstrating the
flexibility of the platform. Furthermore, central bank dashboards and analytical tools
can be developed to provide central banks with a more real-time, dynamic and
comprehensive view of their CBDC on the platform.

7.1.2 Foreign and domestic use of CBDC
Certain transaction types were intentionally omitted from the scope of the pilot due
to the potentially significant policy implications detailed below that need careful
consideration and further discussion before conducting such transactions with a
broader ecosystem.
(i)

Domestic transactions using a domestic currency: could challenge
and compete with existing local payment systems, such as the RTGS.

(ii)

Domestic transactions in a foreign CBDC: raises the risk of displacing
local currencies.

(iii)

Cross-border transactions using a currency which is foreign to both
counterparties: despite the prevalence of this in international trade, it
raises similar concerns about displacing local currencies. This challenge is
particularly salient for EMDEs.

50

See BISIH (2022).

51

For example, the e-THB existed intraday during the pilot to ensure compliance with Thailand’s foreign
exchange regulations, which prohibit non-Thai banks from holding over 200 million THB at the end of each
day to prevent currency speculation. As there was no automated aggregation mechanism during this phase
of the project that would allow the aggregation of e-THB holdings of foreign banks on mBridge with offbridge holdings, e-THB needed to be redeemed off the platform at the end of each day for simpler
reconciliation. See Bank of Thailand (2021).

32

Project mBridge: Connecting economies through CBDC

During the pilot, while participating banks were able to directly transact in
the CBDCs of other jurisdictions on the platform, foreign banks were limited in terms
of how they could move CBDCs on mBridge. Excluding domestic and cross-border
transactions in a currency which is foreign to both counterparties from the pilot
meant that a domestic bank was always involved in at least one leg of any
transaction with regard to the underlying currency. This ensures that significant
amounts of domestic currency cannot accumulate offshore beyond the central
bank’s control, limiting opportunities for the currency to be used for speculative
purposes.
Further in-depth analysis will be needed, and countermeasures
implemented, to mitigate the policy risks associated with the excluded transaction
types before they are included in future phases of mBridge. For example,
considering domestic transactions using domestic currency, mBridge can be further
developed to become an infrastructure for domestic CBDC, if desirable. Additionally,
subject to the decision of the participating central banks, mBridge can enable
domestic and cross-border transactions in a currency which is foreign to both
counterparties after careful consideration by each central bank; for example, they can
set parameters for what currencies their local banks are allowed to hold, the value
limit for each currency they are allowed to keep under custody and what currency
pairs they are allowed to conduct PvP transactions with, thereby mitigating some of
the undesirable outcomes discussed above.

7.1.3 Data privacy and governance
With the involvement of numerous central and commercial banks from multiple
jurisdictions on a shared ledger, data privacy and governance are important
considerations for the success of mBridge. Considerations include how data and
information are shared among the participants and where confidential data resides,
both of which are influenced by the detailed technical architecture and network
deployment.
For the pilot, existing features of the platform in its current stage ensured
that data privacy concerns were adequately addressed. For example, on mBridge,
sensitive data are stored off-chain. On the ledger, data are only shared on a needto-know basis, with only transacting parties and their respective central banks being
privy to the details of a transaction. This is implemented using self-generated key
pairs for pseudo-anonymity that protect user identities and sensitive on-ledger
transaction data. Certain transaction types were also excluded from the scope of the
pilot to ensure compliance with existing data privacy protection laws.52
While the centralised deployment of the pilot provided easy use of the
platform, it also resulted in data being located in a single cloud environment,
heightening privacy concerns. Looking ahead to future pilots, the project team will
explore distributed deployment. Under such a distributed approach, only a small
amount of data is recorded on the blockchain and shared to all participants.

52

For example, non-corporate retail transactions involving Thai banks were prohibited as Thailand’s Personal
Data Protection Act (PDPA) requires end-to-end compliance.

33

Project mBridge: Connecting economies through CBDC

Sensitive and confidential data are stored off-chain in each jurisdiction’s local
database, contained within the local jurisdiction. Even in cases in which such data
need to be stored on the ledger, it would be properly encrypted. Additionally, the
development teams are in the process of evaluating zero-knowledge proof
methodologies to enforce stronger privacy against arbitrary central bank validators.
All of this may serve to alleviate data confidentiality and governance concerns.

7.2 Legal and regulatory considerations
Given that each jurisdiction has different standing rules and regulations, a multijurisdictional CDBC platform raises different legal questions and challenges in each
jurisdiction. During the course of 2022, the mBridge project team sought detailed
legal advice from external counsel in an effort to assess whether, and if so which,
regulatory changes are needed to enable jurisdictional participation in mBridge.53
The legal advice focused on the following key areas:54
a.

Legal categorisation of CBDC: this is the most pivotal and challenging area
across jurisdictions. The typical question is whether CBDC on the platform
would be classed as currency, a representation of funds on account with the
central bank, a debt or something else. In some cases, local laws formally
recognise currency in digital form; in other cases, although not formally
recognised, a statutory framework for issuance of currency in such form can be
achieved with modest upgrades. Where neither of these is the case, an
alternative is to use a transferable digital receipt or certificate of funds held on
account with the central bank.

b.

Central bank participation: central bank powers are generally crafted in broad
terms and are fundamentally focused on the core duties relating to the stability
and integrity of financial systems and maintenance of financial infrastructure.
This provides a useful foundation for central bank participation on a wholesale
CBDC platform. Ancillary aims relating to international linkages can also help
support the ability of central banks to participate on such a platform.

c.

Role of the platform operator: multiple options are available for the platform
operator. Conceptually, to comply with data governance requirements, each of
the central banks could become a participant on the platform, host the platform
on multiple nodes in a decentralised manner and play certain governance roles
that the platform will define and agree on. Nevertheless, tasks that can best be
performed centrally may be identified. In such a case, a decision will need to be
made as to which party or structure is best positioned to perform those central
tasks. In any event, governance of the platform requires a strong interplay

53

External counsel was provided by King & Wood Mallesons, with the support of Al Tamini (as to the laws of
the UAE) and Kudun & Partners (as to the laws of Thailand).

54

A detailed confidential analysis was provided to each jurisdiction with 43 targeted questions across 10 core
areas, totalling over 200 pages. Based on the foregoing, a self-assessment matrix was derived that can be
used by future members who wish to access the platform/become participants to evaluate whether they
would be able to participate under their standing legal frameworks or would require regulatory change.

34

Project mBridge: Connecting economies through CBDC

between platform standards and local rules, as they are fundamentally
intertwined.
d.

AML/CTF/Sanctions: mBridge offers an intermediated infrastructure, in which
commercial banks transact payments in CBDC on behalf of their customers.
Each commercial bank participant on the mBridge platform is obliged to
comply with applicable laws and regulations in relation to AML/CTF/sanctions.
To ensure the commercial participant has taken the necessary steps, the
platform enables transaction-specific certification. This certification is provided
after an off-bridge process, the result of which is translated into a pass/fail
output and attached to the transaction itself. Central banks can also retain full
discretion in relation to CBDC issuance and redemption to align with their
domestic requirements and policies; any additional stakeholder, such as a
platform administrator or operator, will need to factor in compliance – this will
depend on the model adopted.

e.

Settlement finality: in the pilot, settlement finality was achieved through
specially developed legal agreements between each central bank and its
respective commercial banks, further supplemented by operating terms of the
platform tailored on a per-jurisdiction basis (recall subsection 5.1).55 The legal
advice also considered on a per jurisdiction basis whether regulatory changes
would be needed.

f.

Privacy laws: as explained in subsection 7.1.3, the pseudo-anonymity and
privacy protection management functions of mBridge protect user identities
and ensure that data are shared on a need-to-know basis, with only transacting
parties and their respective central banks privy to transaction details. However,
more work and exploration remain to be done to ensure that different data
privacy and governance regulations across jurisdictions are adequately
addressed.

g.

Ancillary areas that may require further focus on the path to a
production-ready system include contract, intellectual property, competition
and anti-trust laws, general conduct of business requirements, record-keeping,
cybersecurity and risk management requirements, liability considerations, and
dispute resolution mechanisms and procedures.

With all of this in mind, given that central bank powers are crafted in broad
terms incorporating core duties relating to the stability and integrity of financial
systems and maintenance of financial infrastructure, wholesale multi-CBDC platform
participation is generally achievable. Nevertheless, depending on the specific
jurisdiction and the legal categorisation of the CBDC, regulatory changes may be
required, or in certain cases preferred, to achieve full legal certainty and clarity. A
strong contractual architecture will also support these aims.

55

Note that e-CNY was an exception. As the e-CNY is already classified as legal tender in Mainland China,
the transfer of e-CNY takes effect from the time of delivery and is deemed final.

35

Project mBridge: Connecting economies through CBDC

8. Conclusion and future roadmap
The work completed to date as part of Project mBridge demonstrates that a tailored
multi-CBDC platform solution to tackling the limitations of today’s cross-border
payment systems is a realistic and achievable goal. By providing a shared platform
on which participants can conduct peer-to-peer payments directly in the safety of
central bank money across multiple jurisdictions, the mBridge pilot and
accompanying analysis confirmed that a common multi-CBDC platform can improve
cross-border payment speed and efficiency, reduce settlement risks and support the
use of local currencies in international payments. All of this was accomplished while
taking into careful consideration any potential policy, macroeconomic, regulatory
and legal implications.
Equipped with the lessons from the pilot and earlier phases of the project,
Project mBridge will continue its work. This includes the technology-build and
testing – including improving on existing functionalities and adding new
functionalities to the platform – in an effort to move from the current pilot phase
towards MVP and eventually a production-ready system (see appendix on project
stages).
In 2023 and 2024, the roadmap for mBridge will focus on the following:

achieving automated interoperability with domestic payment systems;

integrating FX price discovery and matching into the platform;

introducing liquidity management tools such as transaction queueing and
priority management;

evaluating the role of central bank participants in providing liquidity;

improving data privacy-preserving tools;

continuing to develop the legal framework, and platform terms and conditions;

taking further inventories of policy, regulatory and compliance considerations;

evaluating decentralised deployment through a lens of data-privacy and legal
considerations, and in tandem determining the remit and structure of a
centralised governance role;

testing and piloting more business use cases and transaction types;

including additional jurisdictions and participants; and

exploring more services that the private sector can add to the platform.

36

Project mBridge: Connecting economies through CBDC

References
Asian Development Bank (2021): Redefining strategic routes to financial resilience
in ASEAN+3, December.
Bang-Jensen, J and G Gutin (2018): “Basic terminology, notation and results”, in J
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in Mathematics, June, pp 1–34.
Bank of Canada and Monetary Authority of Singapore (2019): Jasper-Ubin design
paper: enabling cross-border high-value transfer using distributed ledger
technologies, May.
Bank of Thailand and Hong Kong Monetary Authority (2020): Inthanon-LionRock:
leveraging distributed ledger technology to increase efficiency in cross-border
payments.
Bank of Thailand (2021): Measure to prevent Thai baht speculation, January,
www.bot.or.th/English/FinancialMarkets/ForeignExchangeRegulations/Measure_t
o_Prevent_ThaiBaht_Speculation/Pages/default.aspx.
Bank for International Settlements (BIS) (2021): “CBDCs: an opportunity for the
monetary system”, Annual Economic Report 2021, Chapter III, June.
Bech, M, U Faruqui and T Shirakan (2020): “Payments without borders”, BIS
Quarterly Review, March.
Bech, M and H Holden (2019): “FX settlement risk remains significant”, BIS
Quarterly Review, December.
BIS, Bank of Canada, European Central Bank, Bank of Japan, Sveriges Riksbank,
Swiss National Bank, Bank of England, Board of Governors Federal Reserve
System (2020): Central bank digital currencies: foundational principles and core
features, October.
BIS, Committee on Payments and Market Infrastructures, International Monetary
Fund, and World Bank Group (2022): Options for access to and interoperability of
CBDCs for cross-border payments, July.
BIS Innovation Hub (BISIH) (2022): Using CBDCs across borders: lessons from
practical experiments, June.
BISIH, the Hong Kong Monetary Authority, the Bank of Thailand, the Digital
Currency Institute of the People’s Bank of China and the Central Bank of the
United Arab Emirates (2021a): Inthanon-LionRock to mBridge: building a multi
CBDC platform for international payments, September.

37

Project mBridge: Connecting economies through CBDC

BISIH, Bank of France and Swiss National Bank (2021b): Project Jura: cross-border
settlement using wholesale CBDC, December.
BISIH, the Hong Kong Monetary Authority, the Bank of Thailand, the Digital
Currency Institute of the People’s Bank of China and the Central Bank of the
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international payments, November.
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of Singapore, and South African Reserve Bank (2022): Project Dunbar:
international settlement using multi-CBDCs, March.
Bindseil, U and G Pantelopoulos (2021): “Towards the holy grail of cross-border
payments”, European Central Bank Working Paper Series, no 2693, August.
Boar, C, S Claessens, A Kosse, R Lecklow and T Rice (2021): “Interoperability
between payment systems across borders”, BIS Bulletin, no 49.
Board of Governors of the Federal Reserve System (2022): The US dollar in the
age of digital transformation, January.
Carstens, A (2021): “Central bank digital currencies: putting a big idea into
practice”, remarks at the Peterson Institute for International Economics
discussion on “Central Bank Digital Currencies”, Basel, 31 March.
Casu, B and R Wandhofer (2017): “The future of correspondent banking crossborder payments”, SWIFT Institute Working Papers, no 1.
Committee on Payment and Settlement Systems (CPMI) (2012): Payment,
clearing and settlement systems in CPSS countries, vol 2, November.
——— (2018): Central bank digital currencies, March.
——— (2022): Facilitating increased adoption of payment versus payment (PvP),
July.
CPMI and International Organization of Securities Commissions (IOSC) (2012):
Principles for financial market infrastructures, April.
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fault tolerance from weak certificates”, Cryptology ePrint Archive, no 625.
European Central Bank and Bank of Japan (2019): Project Stella: synchronised
cross-border payment, June.

38

Project mBridge: Connecting economies through CBDC

Financial Stability Board (FSB) (2020): Enhancing cross-border payments stage 3
roadmap, October.
Giblin, R, J Lindstrom and D Kahil (2021): “Envisioning to delivery – PoC,
prototypes, pilots and MVP”, Danikahil, January,
https://danikahil.com/2021/01/envisioning-to-delivery-poc-prototypes.html.
Group of Seven (G7) (2021): Public policy principles for retail central bank digital
currencies, October.
Hafid, A, A Hafid and M Samih (2020): “Scaling blockchains: a comprehensive
survey”, IEEE Access, July.
International Monetary Fund (IMF) (2020): Digital money across borders: macrofinancial implications, September.
Lamport, L (1978): “The implementation of reliable distributed multiprocess
systems”, Computer Networks, vol 2, May, pp 95–114.
Lamport, L, R Shostak and M Pease (1982): “The Byzantine generals problem”,
ACM Transactions on Programming Languages and Systems, vol 4, no 3, July,
pp 382–401.
Oliver Wyman and JP Morgan (2021): Unlocking $120 billion value in crossborder payments, November.
Rice, T, G von Peter and C Boar (2020): “On the global retreat of correspondent
banks”, BIS Quarterly Review, March.
Saudi Central Bank and Central Bank of the United Arab Emirates (2020): Project
Aber, Saudi Central Bank and Central Bank of the UAE joint digital currency and
distributed ledger project, November.
Shimizu, J (2019): “Exploring local currency usage to reduce exchange rate risks
in Asia”, ASEAN+3 Macroeconomic Research Office, January, www.amroasia.org/exploring-local-currency-usage-to-reduce-exchange-rate-risks-in-asia/.
Yin, M, D Malkhi, M Reiter, G Golan Gueta and I Abraham (2019): “HotStuff: BFT
consensus in the lens of blockchain”, https://arxiv.org/abs/1803.05069v6, July.

39

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Appendix: Project stages
Proof-of-concept (PoC): a method to test and validate a technology or approach
within a limited time window. It typically has less functionality than a prototype. The
experience and knowledge gained from a PoC informs on the feasibility of the
product. A PoC is comparable to research when it is not clear whether an idea can
be brought to life and whether to proceed with the development of the product.
Prototype: While a PoC focuses on one or just a few aspects of a product, a
prototype is a working model of several aspects of the product. A prototype is
comparable to a draft of a full product and is built to test the product’s design,
usability, and often functionality. While a PoC is typically used only internally, a
prototype can also be used to attract users. Furthermore, it forms a basis for a
minimum viable product. While the main goal of a prototype is testing, building a
prototype helps to get a preview at how real people interact with a product. The
development team can gather users’ feedback and make changes to the prototype
or create a new one. Prototyping is also useful for idea generation.
mBridge path towards a production setting

Graph A1

Source: Project team’s adaption of Giblin et al (2021).

Pilot: Pilots are often used as the first stage of a new policy or service rollout. Rather
than a test or experiment, pilots are a ‘live’ activity, usually with a small group of real
users receiving the new service.
Minimum viable product (MVP): a minimum version of a final product and is
delivered to the market right away. It is typically simple, appealing, and bug-free. An
MVP is a version of a product that has just enough features to stay viable. It only has
the core functionality. Delivering an MVP to the market allows for immediate
feedback on the product’s value. See BIS Innovation Hub et al (2021a) and Giblin et
al (2021).

40

Project mBridge: Connecting economies through CBDC

Appendix: Technical design
Blockchain API interface
The API interface described in Table A1 below is the API for the mBridge ledger. This
API is the API between the application layer and the blockchain. These APIs invoke
smart contracts on the blockchain. The ISO 20022 compliant API at the application
layer is not detailed here.
API interface

Table A1

Use case

API ID

Function

Issuance mode 1: issuance
initiated from mBridge

API-1.1

Issuance request

API-1.2

Compliance check result

API-1.3

Off-bridge payment
system execution result

Issuance mode 2: issuance
initiated from off-bridge payment
system

API-2.1

Issuance request

Redemption mode 1: redemption
initiated from mBridge

API-3.1

Redemption request

API-3.2

Compliance check result

API-3.3

Off-bridge payment
system execution result

Redemption mode 2:
redemption initiated from offbridge payment system

API-4.1

Redemption request

API-4.2

Institutional confirmation
information

Cross-border payment

API-5.1

Payment request

Foreign exchange

API-6.1

PvP request

Onboarding

API-7.1

Add/modify onboarding
request

Onboarding

API-7.2

Approve onboarding
request

41

Project mBridge: Connecting economies through CBDC

Technology stack
Technology stack

Table A2

Components

Implementation

Description

Core framework

Java Spring Boot

Mainstream Java frameworks

Microservices framework

Spring Cloud

Distributed task scheduling

Quartz

Service registry

Eureka

Mainstream Microservices
framework
Open-source industry
standard library
Spring Cloud registry

Operating system

CentOS

Backend service database

MySQL

JDK

OpenJDK8

Load balancing

Nginx

Smart contract language

Solidity

Blockchain virtual machine

EVM

Blockchain consensus
protocol
Key-value storage

HotStuff+

42

RocksDB

Mainstream server-side
operating systems
Mainstream relational
database
Mainstream stable version of
the JDK
Mainstream web servers and
software load balancers
Mainstream smart contract
language
Mainstream blockchain virtual
machine engine
Top performing O(n)
consensus
Mainstream data storage
methods

Project mBridge: Connecting economies through CBDC

Pseudo-anonymous key pair signing
Pseudo-anonymous key pair signing

Graph A2

43

Project mBridge: Connecting economies through CBDC

mBridge payment and FX PvP flow
Payment flow

44

Graph A3

Project mBridge: Connecting economies through CBDC

FX PvP flow:

Graph A4

45

Project mBridge: Connecting economies through CBDC

Appendix: Project participants and acknowledgements
BIS Innovation Hub
Bénédicte Nolens, Hong Kong Centre Head
Daniel Eidan, Adviser and Solution Architect
Leanne (Si Ying) Zhang, Adviser

Hong Kong Monetary Authority
Colin Pou, Executive Director, Financial Infrastructure Department
Yvonne Tsui, Chief Manager, Fintech Facilitation Office
Brian Lam, Senior Manager, Fintech Facilitation Office
Ting Yuan, Consultant, Fintech Facilitation Office
Frederick Cheung, Manager, Fintech Facilitation Office
Jason Lai, Manager, Fintech Facilitation Office
Bernia Lee, Manager, Fintech Facilitation Office

Bank of Thailand
Vachira Arromdee, Executive Adviser for CBDC Projects
Kasidit Tansanguan, Director, Digital Currency Team
Chaiwat Sathawornwichit, Deputy Director, Office of Corporate Strategy
Witit Synsatayakul, Assistant Director, Digital Currency Team
Tanakorn Kerdrattikal, Assistant Director, Digital Currency Team
Tunyathon Koonprasert, Senior Specialist, Digital Currency Team
Pakaporn Tohwisessuk, Senior Specialist, Digital Currency Team

Digital Currency Institute of the People’s Bank of China
Changchun Mu, Director-General
Yuan Lyu, Director, Innovation Division
Youcai Qian, Deputy Director of R&D II Department
Ying Zhao, Leader of Legal and Compliance Team
Ruiqi Zhao, Strategy Planning Team
Lin Su, Business Development Team
Li Li, Strategy Planning Team
Shiyue Sun, Business Development Team

46

Project mBridge: Connecting economies through CBDC

Mingming Zhang, Business Development Team
Qingjie Chen, Research & Development II Team
Shaohua Liu, Research & Development II Team

Central Bank of the United Arab Emirates
Saif Al Dhaheri, Assistant Governor – Strategy, Financial Infrastructure and Digital
Transformation of the Central Bank of UAE
Shu Pui Li, Advisor – Governor’s Office
Herman Schueller, Head – Digital Transformation
Michael Caselberg, Chief Transformation Officer
Paul Kayrouz, Chief Fintech Officer
Hafid Oubrik, Director – Financial Infrastructure Management
Jonathan Holman, Head of Strategic Change & Business Analysis
Husam Habannakeh, Senior Manager, – Fintech Development
Pranav Mehta, CFA, Manager – Fintech Development

Vendors
Accenture
King & Wood Mallesons

Commercial bank pilot participants
Hong Kong SAR banks
Bank of China (Hong Kong) Limited
Bank of Communications Co., Ltd. Hong Kong Branch
Industrial and Commercial Bank of China (Asia) Limited
Standard Chartered Bank (Hong Kong) Limited
The Hongkong and Shanghai Banking Corporation Limited

Thailand banks
Bangkok Bank Public Company Limited
Bank of Ayudhya Public Company Limited
Kasikornbank Public Company Limited
Siam Commercial Bank Public Company Limited
The Hongkong and Shanghai Banking Corporation Limited (Bangkok Branch)

47

Project mBridge: Connecting economies through CBDC

Mainland China banks
Agricultural Bank of China Limited
Bank of China Limited
Bank of Communications
China Construction Bank
Industrial and Commercial Bank of China

UAE banks
Bank of China Ltd. – Abu Dhabi
First Abu Dhabi Bank P.J.S.C.
HSBC Bank Middle East
Industrial and Commercial Bank of China Limited – Abu Dhabi Branch
Standard Chartered Bank (UAE)

Acknowledgements
Special thank you to Cecilia Skingsley, Ross Leckow, Morten Bech, Jon Frost, Raphael
Auer and Codruta Boar for their inputs to this report, and to our private sector
partners John Velissarios, Ousmene Mandeng, Jessica Johnson, Nalin Lad, Alex
Ojinnaka, Peter De Rooij, Urszula McCormack, Evan Manolios and KPMG Advisory
(Hong Kong) Limited for supporting this project.