This white paper explores the proposal for an intergovernmental cryptocurrency as outlined by the Center for Regulatory Effectiveness (CRE), a regulatory think tank led by Jim Tozzi. While not a technical implementation document, the proposal presents a regulatory and governance framework for how digital currencies could be jointly managed by multiple sovereign states.
This paper analyzes the feasibility of such a system in light of current central bank digital currency (CBDC) initiatives around the world. It compares the CRE model to real-world efforts such as Project mBridge, discusses key regulatory and political challenges, and offers a phased approach for moving toward greater cross-border digital currency coordination.
1. Introduction
The rapid evolution of digital payment systems and CBDCs has created both opportunities and risks. Governments are experimenting with sovereign digital currencies to improve financial inclusion, enhance transaction efficiency, and reduce reliance on private crypto-assets.
Yet, while individual nations are building their own CBDCs, cross-border interoperability remains a major gap. The CRE’s proposal for an “intergovernmental cryptocurrency” provides one possible blueprint for addressing this challenge.
This paper does not advocate the immediate creation of a global digital currency, but rather assesses the regulatory and cooperative principles necessary to move in that direction.
2. Overview of the CRE Proposal
In an article titled An Intergovernmental Cryptocurrency, the Center for Regulatory Effectiveness lays out five key principles:
| Section |
Summary |
| (1) Governance |
An international body would oversee the cryptocurrency, ensuring transparency and legal alignment across member nations. |
| (2) Interoperability |
The system must integrate with both traditional and digital financial systems, enabling seamless cross-border payments. |
| (3) Regulatory Oversight |
Strong anti-money laundering (AML), fraud detection, and consumer protection mechanisms are required. |
| (4) Transparency and Auditing |
Transactions would be traceable and auditable without undermining user privacy. |
| (5) Stakeholder Involvement |
Development would be inclusive of governments, financial institutions, technologists, and the public. |
Note: While Jim Tozzi is not explicitly listed as the author, these ideas reflect his regulatory philosophy and originate from his organization’s platform.
3. Comparison with Real-World CBDC Projects
| Project |
Governance Model |
Interoperability |
Cross-Border Capability |
Status |
| Digital Euro |
ECB-led, EU governance |
High |
Limited |
In pilot |
| e-CNY (Digital Yuan) |
National (PBOC) |
Moderate |
Limited |
Advanced pilot |
| FedNow (US) |
National (Fed) |
High (domestic) |
None |
Launched (real-time payments) |
| Project mBridge |
Joint (BIS + Asia/Middle East) |
High |
High |
Ongoing pilot |
| DCash (Eastern Caribbean) |
Regional (ECCB) |
Moderate |
Moderate |
Launched, limited adoption |
Closest match: Project mBridge, a joint initiative by China, Hong Kong, Thailand, and the UAE under the BIS Innovation Hub, is testing a shared platform for real-time cross-border CBDC settlement.
4. Key Challenges to an Intergovernmental Cryptocurrency
4.1 Sovereignty Concerns
National governments are unlikely to relinquish full control over currency issuance and monetary policy to an international body.
4.2 Legal Fragmentation
Each country has its own legal, tax, and privacy frameworks. Harmonizing these under a single crypto system would be a monumental task.
4.3 Trust and Transparency
Intergovernmental systems require high levels of mutual trust, especially in areas like data sharing, transaction privacy, and enforcement mechanisms.
4.4 Technological Standardization
While interoperability is achievable, aligning technical standards across central banks remains a complex and politically sensitive endeavor.
5. Regulatory and Governance Design Considerations
If an intergovernmental cryptocurrency were to be pursued, the following design pillars would be critical:
| Pillar |
Description |
| Layered Governance |
Tiered model with national nodes reporting to a central coordination authority. |
| Regulatory Sandboxes |
Allow countries to test cross-border digital settlements without committing to full integration. |
| Privacy-by-Design |
Enable traceability for compliance while protecting individual privacy through zero-knowledge proofs or similar tech. |
| Public Participation |
Include public and civil society voices in design discussions to prevent elite-only decision-making. |
6. ️ A Phased Approach: From National to Intergovernmental CBDCs
-
Domestic CBDC Launches
Nations continue developing individual CBDCs to modernize payment infrastructure.
-
Bilateral and Regional Experiments
Projects like mBridge, Dunbar, and the EU digital wallet test cross-border use.
-
Multilateral Standardization Frameworks
Global regulators (e.g. BIS, IMF, FATF) establish shared compliance, technical, and governance standards.
-
Pilot Intergovernmental System
Small group of trusted nations builds a prototype intergovernmental cryptocurrency with limited use cases (e.g., trade settlements, aid disbursement).
-
Scaled Intergovernmental Integration
Broader adoption depending on success metrics, geopolitical stability, and regulatory alignment.
7. Policy Recommendations
-
Encourage BIS to Expand Multinational CBDC Pilots
Build on mBridge and other regional efforts by including more diverse partners.
-
Promote Open Standards and APIs
Central banks should agree on interoperable protocols early in CBDC design.
-
Foster Global Dialogue on Governance Models
Leverage platforms like the G20, IMF, and UN to begin shaping long-term frameworks for shared digital currencies.
-
Include Non-State Stakeholders
Integrate feedback from the fintech sector, consumer advocacy groups, and academia to balance innovation and rights protection.
8. Conclusion
The vision outlined by the Center for Regulatory Effectiveness represents a regulatory first-mover framework — not a technical implementation. Its strength lies in raising critical questions about how governance, interoperability, and compliance should be approached in a future where digital currencies operate across borders.
While a fully intergovernmental cryptocurrency may not be immediately viable, the regulatory scaffolding proposed could guide next-generation CBDC cooperation, starting with regional pilots and scaling toward broader integration.
References
-
Center for Regulatory Effectiveness (2023). An Intergovernmental Cryptocurrency. Link
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BIS Innovation Hub (2023). Project mBridge.
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ECB (2024). Digital Euro Preparation Phase Report.
-
IMF (2023). Central Bank Digital Currencies: Global Roadmap.
-
FATF (2023). Updated Guidance for Virtual Assets and VASPs.
APPENDIX
This Appendix was produced by the Center for Regulatory Effectiveness.
It should be noted that the above publication by ChatGPT is far more comprehensive than anything CRE has published in a single publication. We reach this conclusion because CRE has been publishing on the subject under discussion for a considerable time period and it is virtually impossible for CRE to take the steps necessary to address all relevant data produced by CRE over a forty year period into one publication as is the case with the ChatGPT publication. It is an even greater challenge for CRE to perform the same process for the myriad of comments it receives from its followers.
Hopefully CRE’s conclusion that the United States government is in a free fall to insolvency is incorrect. It is for this reason that it is not recommending that it be implemented immediately. That said, too much is at stake to not begin an informed discussion of the remedy presented herein, even with its attendant shortcomings, as the preferred alternative to the conventional solution of simply printing and issuing additional currency to address burgeoning budget deficits.