The Senate pushed the Clarity Act into September. After months of negotiation, the market structure bill went into the August recess without a final vote, leaving the rules for digital asset markets unsettled for at least several more weeks.
Meanwhile, banks aren't waiting.
They are issuing tokenized deposits, testing onchain settlement, and working out how to move commercial bank money on new, compliant rails. The question has moved past whether banks will put deposits onchain. They already are.
The question now is whether the systems they are building can talk to one another. And that is the one question no bill in Congress can answer.
JPMorgan has moved institutional payments through its Kinexys platform for years, reporting more than $3 trillion in cumulative transaction volume, and now offers JPMD, a deposit token for institutional clients. Citi runs Token Services for cross-border treasury across four markets. In June, seventeen major financial institutions, including JPMorgan, Bank of America, Citi and Wells Fargo, announced that The Clearing House will clear and settle tokenized deposits onchain, with a reported target of 2027.
The same trend is emerging beyond the largest institutions. In March, Huntington, First Horizon, M&T Bank, KeyCorp and Old National became design partners on the Cari Network, a bank-governed tokenized-deposit network led by former Comptroller of the Currency Gene Ludwig. Over the last four months, more than 30 institutions have joined the network, with another 40 in active discussion, representing institutions with more than $10 trillion in combined assets. The network, powered by Prividium, a privacy-focused layer 2 built on ZKsync, is designed to let regulated banks issue, transfer, and redeem tokenized deposits while keeping those deposits on their balance sheets.
These are not science projects. They are attempts to solve a practical problem: moving money and collateral around the clock while preserving the regulatory protections that make commercial bank deposits useful in the first place.
Here is the part the industry keeps talking past. A tokenized deposit is a claim on one specific bank. A JPMorgan token dollar and a regional bank's token dollar are different liabilities on different balance sheets, and no technology makes them the same asset.
That means interoperability between deposit networks was never going to come from a messaging standard or a token bridge. It comes the way it has always come in banking: through clearing. When money moves between banks, the sending bank's token is redeemed, the receiving bank issues its own, the obligation between the two institutions is recorded and netted against everything else flowing between them, and the residual settles in central bank money. That machinery, not the token, is what makes one bank's dollar spend like another's. It was true when clearing houses formed in the 19th century, and it is true onchain.
The engineering challenge is that this machinery now has to meet standards the old rails never faced simultaneously: banks will not publish counterparties, amounts, or payment data to a public ledger; banks will not run their business on infrastructure a competitor controls; and banks will not net obligations on a ledger they cannot independently verify. Privacy, neutrality, and verifiability, all at once. This is an architecture problem, and it is being solved as one: each institution operating its own ledger, cryptographic proofs allowing networks to verify transfers without exposing the underlying data, and settlement anchored to neutral infrastructure that no participant owns. That design philosophy is what we build toward at Matter Labs, and it is the direction much of the industry is converging on from different starting points.
Clarity does not regulate tokenized deposits, and it will not make bank networks interoperable. No statute can turn one bank's liability into another's. What legislation and regulators can do is remove the uncertainty that sits around the edges of these projects.
Clarity would settle jurisdiction over digital asset markets, defining the competitive environment in which bank-issued money will operate alongside regulated stablecoins. The more direct work sits with the banking agencies. Industry bodies have been specific about what is missing: the Global Financial Markets Association's April 2026 report on digital money lists uniform treatment of tokenized deposits across jurisdictions, and guidance on transferring tokenized deposits outside the issuing bank's network, among the open gaps. Those two items are the regulatory unlock for interbank tokenized money. A bank will connect its deposit system to another institution's network when it knows how compliance responsibility, customer data protection, and risk are governed across that connection. Not before.
Some worry that a wave of bank-run networks means a new generation of walled gardens. That concern misreads where the fork in the road actually is. Banks building private, permissioned networks is not the failure mode. It is how regulated institutions have always built, and it is the appropriate way to handle deposit data. The fork is between private networks that are isolated by construction and private networks that are connected by architecture.
In one future, each network is an island, and moving value between them recreates the patchwork of bilateral connections that tokenization was meant to retire. In the other, networks stay private where privacy belongs, interoperate through proofs and clearing rather than through exposure, and settle against neutral infrastructure. The technology for the second future exists today.
This is where Washington re-enters the story. Connecting to another institution's network is a risk decision, and under regulatory uncertainty the rational default for every bank is isolation, because a closed system only has to answer for itself. Every month without settled rules quietly rewards the walled garden. Clarity will not regulate tokenized deposits directly, but passing it settles the perimeter of digital asset markets, completes the framework the GENIUS Act started for stablecoins, and tells bank boards and examiners that building on shared onchain infrastructure is a supervised activity with known rules rather than a bet on future forbearance.
The architecture determines whether bank networks can talk to one another. Regulatory certainty determines whether they will. Banks are making the first decision right now, network by network. In September, Washington gets to make the second.