At a Glance
Always‑on settlement shifts liquidity risk from windowed buffers to continuous control, forcing 24/7 treasury, stricter resilience standards, and disciplined choices on tokenized infrastructure and vendors.

Background
Always‑on payments and faster securities settlement compress the time between customer intent and irrevocable balance‑sheet impact. As settlement moves from windowed cycles to continuous execution, intraday liquidity stops behaving like a planning exercise and starts behaving like a real‑time control problem: behavior‑driven, sentiment‑sensitive, and operationally unforgiving during nights, weekends, and market stress.
In parallel, policy and supervisory frameworks are narrowing what “permissible” digital‑asset activity looks like inside regulated banking organizations, with a consistent emphasis on governance, operational resilience, third‑party oversight, and auditable controls. Within those boundaries, tokenized deposits and permissioned ledgers are being evaluated as potential complements to modern real‑time rails for specific use cases—particularly where shared state, atomic settlement, and observability change the control surface in ways that conventional messaging cannot replicate.
Liquidity transformation and real‑time resilience
Batch processing and settlement windows historically created a form of friction that doubled as a stabilizer: netting, intraday float, and cut‑off times provided time to source funding and reconcile positions. Continuous settlement removes that buffer. The practical result is a tighter coupling between payments activity and immediate funding needs, increasing the speed at which liquidity stress can propagate across products, channels, and counterparties.
Changing liquidity dynamics and deposit stability
Loss of netting efficiency becomes the first‑order mechanical shift. Windowed settlement allows offsetting inflows and outflows to reduce peak funding requirements. In a gross, real‑time world, liquidity must be available at the instant of each transaction, raising demand for immediately mobilizable high‑quality liquid assets and increasing the opportunity cost of idle balances.
Continuous intraday fragility follows because exposure extends beyond traditional operating hours. When withdrawals and outbound payments can clear instantly, confidence shocks can translate into balance‑sheet movement before escalation paths, market‑liquidity assumptions, and collateral processes have time to respond.
Asset‑liability compression emerges as a second‑order effect. Deposits that can exit at any time behave more like on‑demand liabilities under stress. That can increase pressure to hold larger liquidity buffers, narrowing tolerance for maturity transformation and tightening the link between liquidity policy and credit capacity.
Risk management responses
Executive responses tend to converge on redesigning the funding architecture and the control plane, not simply adding balances. The trade‑off is explicit: higher resilience and settlement certainty versus a higher structural liquidity footprint and greater dependency on continuously available technology.
Funding architecture
- Prefunding through higher balances in central bank or settlement accounts to protect settlement finality under stress
- Just‑in‑time liquidity via automated funding movements to reduce idle balances while increasing reliance on highly resilient real‑time infrastructure
- Dynamic collateral mobility to secure intraday credit and meet margin calls with fewer manual steps and tighter timing constraints
- Velocity controls including anomaly detection and transaction limits to slow abnormal outflows and create time for governance escalation
Technical and operating model evolution
- Continuous monitoring of payment‑rail liquidity positions, correspondent accounts, and liquidity buffers with real‑time reconciliation
- Automated liquidity sweeps and contingency funding triggers to prevent technical shortfalls from becoming settlement failures
- Real‑time stress simulation that links liquidity dynamics to solvency signals and funding market conditions
- Transition to a 24/7/365 treasury operating model, supported by follow‑the‑sun staffing and tightly governed automation
Blockchain versus conventional real‑time architecture
Modernized conventional rails increasingly combine ISO 20022 messages, APIs, and richer data to improve coordination. They still require synchronization and reconciliation across separate ledgers with different owners, operating hours, and exception processes. Permissioned ledgers change the architecture by creating shared state and enabling atomic execution, which can reduce settlement risk in specific workflows—while introducing new concentration, governance, and operational failure modes that must be addressed with bank‑grade controls.
Use cases with material ledger advantage
- Atomic DvP and PvP where asset and cash exchange occur simultaneously, reducing principal risk and reducing the need for conservative prefunding buffers
- Tokenized interbank liabilities enabling balance‑sheet transfer mechanisms outside traditional cut‑offs, subject to legal finality and supervisory acceptance
- Programmable liquidity controls that embed conditional logic and policy constraints at execution time rather than relying on post‑facto monitoring
- Real‑time collateral movement for margin and liquidity optimization where timing, auditability, and operational certainty are decision‑critical
- Supervisory observability through auditable transaction views that support faster investigations and clearer control evidence
Decision criteria executives should insist on
Whether a shared ledger is justified should be decided case‑by‑case, anchored in measurable risk reduction or control improvement rather than technology novelty. A decision framework typically tests the following:
- Settlement finality model including legal enforceability, irrevocability, and the design of reversals and error handling
- Governance and control structure covering participation rules, change management, and incident authority in multi‑party environments
- Interoperability with core banking, treasury, risk engines, identity, and AML monitoring, including ISO 20022 alignment where relevant
- Operational resilience across latency, throughput, failover, and cyber response in a 24/7 operating model
- Cost and scalability viewed through the lens of peak liquidity demand, control evidence generation, and integration burden
- Regulatory and examiner acceptance including auditability, third‑party dependencies, and supervisory access to information
Provider landscape and delivery model
Delivery models for tokenized settlement are converging on hybrid structures because the binding constraint is not software alone; it is the movement of regulated liabilities and the governance that makes that movement credible to supervisors and market participants. Bank‑led consortia can support interoperability and shared rules, core providers can orchestrate integration and operational stability, and fintechs can contribute custody‑adjacent capabilities and programmable infrastructure patterns.
For executives, the key is to separate technology delivery from risk accountability. In most viable models, banks retain primary risk ownership for settlement, compliance, and customer outcomes; participants share compliance and control evidence where appropriate; and network governance defines change authority, admission standards, and incident operating procedures.
Mission‑critical vendor standards
Always‑on settlement infrastructure must meet or exceed legacy payment‑rail reliability while addressing distributed‑ledger‑specific risks. “Pilot‑grade” controls rarely survive the move to production because 24/7 settlement eliminates convenient maintenance windows, reduces tolerance for incident ambiguity, and increases the cost of exception processing.
Technical foundations
- Native ISO 20022 interoperability and modular API integration that supports end‑to‑end traceability across internal and external systems
- Confidential transaction controls and hardened key management with clear segregation of duties and strong recovery processes
- Deterministic, high‑throughput atomic settlement capabilities with predictable performance under peak and stress conditions
Operational resilience
- Active‑active geographic redundancy with automated failover that avoids manual coordination across parties
- Recovery objectives aligned to critical payment and settlement tolerances, supported by continuous testing and evidence
- Continuous incident detection and a 24/7 operational response model with predefined escalation and customer impact controls
Governance and auditability
- Real‑time audit transparency with role‑based visibility that supports both internal assurance and supervisor expectations
- Mature control frameworks mapped to financial, operational, and cybersecurity risk requirements
- Secure, governed smart‑contract or rules‑engine upgrade mechanisms that preserve finality, integrity, and change traceability
Third‑party risk, data protection, and exit governance
In a continuous settlement model, vendors and network operators become critical third parties because their availability, cyber posture, and change discipline directly affect a bank’s ability to meet settlement obligations. Interagency guidance emphasizes risk‑based due diligence, ongoing monitoring, and contract provisions that preserve audit rights and supervisory access, all of which become more consequential when settlement is always‑on.
Core risk domains for oversight
- Cybersecurity and resilience including secure identity, continuous vulnerability management, rapid incident notification, and explicit coverage of smart‑contract and key‑management failure modes
- Business continuity with documented redundancy, fallback processing, and infrastructure dependency mapping across cloud, telecom, and key personnel
- Fourth‑party exposure requiring transparent subcontractor inventories, contractual control flow‑downs, and evidence that vendors can govern their own critical dependencies
- Audit and regulatory access with enforceable audit rights, certification validation, and financial‑condition monitoring
- Data protection and consumer compliance including tokenization safeguards, privacy obligations, and rights management in always‑available channels
- Exit and substitutability through data return or destruction commitments, transition planning, and immediate access revocation capabilities
The governance challenge is to avoid creating a de facto single point of failure through concentration on a vendor platform or consortium operator. Substitutability is rarely achieved by contract language alone; it requires sustained architectural discipline, portability testing, and clear operational playbooks.
Implementation path and adoption horizon
The industry’s move from pilots to scaled deployment is more likely to be gated by integration, standards, and supervisory alignment than by ledger performance alone. Continuous settlement shifts the economics from “processing cost” to “liquidity value,” making the business case sensitive to funding spreads, collateral availability, and the cost of 24/7 operational readiness.
Phased progression
- Pilot 0–2 years focusing on internal liquidity controls, narrow corridors, and proof of operational evidence generation
- Limited production 2–4 years in institutional use cases where precision settlement and resilience can be demonstrated under supervision
- Broad deployment 5 years and beyond where tokenized settlement becomes a material liquidity layer across multiple products and counterparties
Structural gating factors executives should plan for
- Legacy core integration complexity and the operational cost of real‑time reconciliation across multiple ledgers
- Interoperability and identity standards maturity, including consistent message semantics and entitlement models
- Rising supervisory expectations for resilience, cyber controls, audit evidence, and third‑party risk governance
- Continuous‑operations performance requirements, including testing regimes that reflect nights, weekends, and stress periods
- Competitive dynamics where tokenized alternatives reshape deposit behavior and the speed of funds movement
Strengthening executive readiness for continuous settlement decisions
Across liquidity transformation, architecture selection, and third‑party oversight, the recurring executive problem is sequencing: which capabilities must be proven first to reduce decision risk, and which dependencies create non‑obvious failure modes in a 24/7 environment. A structured maturity assessment makes those dependencies explicit by benchmarking treasury controls, resilience engineering, data and monitoring discipline, and governance effectiveness against the demands of continuous settlement.
Used well, the assessment becomes a control artifact rather than a strategy document. It helps leadership test readiness for always‑on liquidity monitoring, validate whether automation and velocity controls are governed tightly enough for examiner scrutiny, and identify where tokenized infrastructure would add control value versus merely shifting risk. The DUNNIXER Digital Maturity Assessment can be applied to quantify capability gaps that affect settlement finality, auditability, cyber resilience, and exit governance, improving decision confidence on when to scale, when to constrain scope, and how to sustain supervisory transparency once production begins.
Reviewed by

The Founder & CEO of DUNNIXER and a former IBM Executive Architect with 26+ years in IT strategy and solution architecture. He has led architecture teams across the Middle East & Africa and globally, and also served as a Strategy Director (contract) at EY-Parthenon. Ahmed is an inventor with multiple US patents and an IBM-published author, and he works with CIOs, CDOs, CTOs, and Heads of Digital to replace conflicting transformation narratives with an evidence-based digital maturity baseline, peer benchmark, and prioritized 12–18 month roadmap—delivered consulting-led and platform-powered for repeatability and speed to decision, including an executive/board-ready readout. He writes about digital maturity, benchmarking, application portfolio rationalization, and how leaders prioritize digital and AI investments.
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- https://s-pro.io/blog/system-integration-in-banking
- https://www.gauthmath.com/solution/1813508034127989/Question-90f-1-What-does-distributed-ledger-technology-bring-to-transactions-Sel#:~:text=DLT%20is%20trustless%20because%20it,eliminate%20the%20need%20for%20regulation.
- https://www.lightspark.com/knowledge/ach-vs-chips#:~:text=For%20businesses%20looking%20to%20transcend%20the%20limitations,and%20CHIPS%2C%20Lightspark%20offers%20the%20following%20solutions:
- https://www.gtreasury.com/posts/cfo-value-digital-infrastructure-choice#:~:text=Our%20platform%20is%20built%20on%20the%20principle,treasury%20systems%20remains%20fully%20supported%20and%20enhanced.
- https://www.linkedin.com/pulse/rbi-releases-blueprint-modern-bank-soc-techowl-infosec-yd5rf#:~:text=%F0%9F%94%B9%2024x7x365%20resilience%20is%20non%2Dnegotiable%20RBI%20explicitly,centers%2C%20with%20mechanisms%20like%20crisscross%20log%20shipping.
- https://medium.com/adeo-tech/the-crucial-role-of-iag-in-managing-the-explosion-of-identity-providers-683b73791d79#:~:text=Audit%20and%20compliance%20challenges:%20Lack%20of%20centralization,comply%20with%20regulations%20(ISO%2027001%2C%20GDPR%2C%20NIS2).
- https://www.federalregister.gov/documents/2023/06/09/2023-12340/interagency-guidance-on-third-party-relationships-risk-management
- https://www.federalregister.gov/documents/2023/06/09/2023-12340/interagency-guidance-on-third-party-relationships-risk-management#:~:text=The%20Board%2C%20FDIC%2C%20and%20OCC,organizations%20supervised%20by%20the%20agencies.
- https://www.federalreserve.gov/publications/third-party-risk-management-a-guide-for-community-banks.htm#:~:text=In%20June%202023%2C%20the%20Board,substitute%20for%20the%20TPRM%20Guidance.
- https://trycomp.ai/what-is-third-party-risk-management
- https://atlan.com/know/data-governance/third-party-risk-management/#:~:text=An%20effective%20third%2Dparty%20risk,Audit%20readiness%20and%20documentation
- https://www.certa.ai/resources/third-party-relationships#:~:text=This%20Guidance%20supersedes%20previous%20guidance,in%20their%20compliance%20management%20program.
- https://kpmg.com/us/en/articles/2023/third-party-risk-management-final-interagency-guidance-reg-alert.html#:~:text=June%202023,%2C%20and%204)%20supervisory%20reviews.
- https://www.federalreserve.gov/frrs/guidance/interagency-guidance-on-third-party-relationships.htm#:~:text=Not%20all%20relationships%20present%20the,organization's%20financial%20condition%20or%20operations.
- https://www.communitybankingconnections.org/articles/2022/i3/reporting-computer-security-incidents#:~:text=In%20summary%2C%20the%20rule%20requires,such%20an%20incident%20has%20occurred.
- https://nordlayer.com/blog/blockchain-security-issues/#:~:text=Blockchains%20are%20vulnerable%20to%20traditional,following%20blockchain%20security%20best%20practices.
- https://www.pcisecuritystandards.org/faq/articles/Frequently_Asked_Question/can-entities-be-pci-dss-compliant-if-they-have-performed-vulnerability-scans-at-least-once-every-three-months-but-do-not-have-four-passing-scans/#:~:text=PCI%20DSS%20requires%20entities%20to,that%20vulnerabilities%20have%20been%20addressed.
- https://static1.squarespace.com/static/6675a0d5fc9e317c60db9b37/t/6982abb3c5cfd2209a98da90/1770171315639/The+Hidden+Plumbing+of+Stablecoins_+vShare.pdf
- https://infobytes.orrick.com/wp-content/uploads/RENEWED-MOTION-TO-INTERVENE.pdf
- https://www.intrustbank.com/article/components-vendor-management-process#:~:text=When%20evaluating%20the%20vendor's%20documents%2C%20think%20about,system%20could%20be%20restored%20within%20that%20time.
- https://www.truework.com/resource-center/blog/truework-security-and-trust-overview#:~:text=Data%20backups%20are%20held%20in%20multiple%20secure,are%20assessed%20for%20effectiveness%20at%20least%20annually.
- https://tink.com/blog/open-banking/psd2-contingency-mechanism/#:~:text=The%20formal%20fallback%20%E2%80%93%20the%20'contingency%20mechanism',want%20to%20change%20anything%20in%20the%20fallback.
- https://www.rivialsecurity.com/blog/assessing-fourth-party-vendor-risk#:~:text=What%20is%204th%20Party%20Vendor%20Risk%20Management?,vendors%20that%20your%20third%2Dparty%20vendors%20rely%20on.
- https://www.ncontracts.com/nsight-blog/september-2025-regulatory-update#:~:text=The%20CFPB%20is%20seeking%20feedback%20on%20its,providers%20can%20charge%20fees%20for%20third%2Dparty%20access.
- https://curity.io/blog/advanced-CIAM-US-CFPB-Section-1033-Compliance/#:~:text=Advanced%20CIAM%20Is%20Key%20to%20US%20CFPB,only%20approved%20users%20and%20only%20context%2Drelevant%20data
- https://www.kybanks.com/kba-files/pdf/prodserv/NContracts_Nvendor_Product_Sheet.pdf#:~:text=Ongoing%20Reviews:%20Provide%20continuous%20risk%20identification%20by,if/when%20vendor%20relationships%20need%20to%20be%20terminated.
- https://www.cutover.com/blog/disaster-recovery-compliance-dora-regulation-challenges#:~:text=For%20example%2C%20legal%20firms%2C%20cloud%20providers%20and,on%20database%20size%2C%20disaster%20recovery%20strategy%2C%20etc.
- https://www.webopedia.com/crypto/banks-leading-digital-asset-tokenization/
- https://www.gfma.org/policies-resources/joint-trades-publish-report-on-the-impact-of-dlt-in-capital-markets/
- https://www.linkedin.com/posts/daniel-smith-fica-a4a89a11_banks-are-finally-moving-onto-blockchain-activity-7384077270690455552-sxAm
- https://www.linkedin.com/posts/varun-paul-fireblocks_tokenised-assets-reached-24-billion-in-2025-activity-7416609966570246144-oOKC
- https://www.thoughtworks.com/en-de/insights/articles/building-stablecoin-infrastructure-banking-institutional-relevance
- https://www.federalreserve.gov/econres/notes/feds-notes/banks-in-the-age-of-stablecoins-implications-for-deposits-credit-and-financial-intermediation-20251217.html#:~:text=The%20rapid%20growth%20of%20stablecoins,profile%2C%20and%20cost%20of%20capital.
- https://www.linkedin.com/posts/varun-paul-fireblocks_tokenised-assets-reached-24-billion-in-2025-activity-7416609966570246144-oOKC#:~:text=interoperability%20gap%20remains-,Varun%20Paul,/IP%20was%20vendor%2Dneutral.
- https://www.thoughtworks.com/insights/articles/building-stablecoin-infrastructure-banking-institutional-relevance#:~:text=Institutionalization.,is%20still%20the%20master%20record.
- https://bvnk.com/blog/blockchain-cross-border-payments#:~:text=%E2%80%8D-,2025%20is%20a%20turning%20point%20for%20cross%2Dborder%20blockchain%20adoption,a%20few%20per%20cent%20today).
- https://www.linkedin.com/posts/daniel-smith-fica-a4a89a11_banks-are-finally-moving-onto-blockchain-activity-7384077270690455552-sxAm#:~:text=Some%20will%20see%20that%20as,The%20rules%20will%20follow%20later.&text=Fr%C3%A9d%C3%A9ric%20N.&text=This%20is%20a%20fascinating%20development,smaller%20banks%20and%20fintech%20startups?&text=The%20balance%20between%20innovation%20and,first%2C%20regulation%20always%20catches%20up.
- https://www.elibrary.imf.org/view/journals/063/2025/011/article-A001-en.xml#:~:text=If%20these%20tokenized%20assets%20meet,tokenized%20assets%20as%20eligible%20collateral.
- https://www.fireblocks.com/report/state-of-stablecoins#:~:text=Respondents%20are%201.5x%20more,efficiency%20and%20top%2Dline%20growth.
- https://www.gfma.org/wp-content/uploads/2025/08/1.-full-report-impact-of-dlt-in-cap-mkts-final-1.pdf#:~:text=The%20use%20of%20DLT%20in%20capital%20markets,system%20safer%20and%20more%20secure%20for%20all.
- https://www.jpmorgan.com/kinexys/documents/JPMC-Kinexys-Project-Epic-Whitepaper-2024.pdf
- https://clsbluesky.law.columbia.edu/2025/10/16/is-it-time-for-a-blockchain-enabled-u-s-sovereign-wealth-fund/#:~:text=The%20lesson%20is%20that%20success%20depends%20less,challenges%20of%20integrating%20blockchain%20into%20institutional%20portfolios.