The closing keynote by Dr Gérardine Goh Escolar, Deputy Secretary-General of the Hague Conference on Private International Law (HCCH), wove the threads of three days of debate into a single narrative about what money is — and who gets to decide. Starting from the giant stone coins of the Yap Islanders and the historical record showing that the earliest monies were ledgers and credit instruments rather than commodities, she argued that money has never been an object: it is a moral, legal and economic institution, and the emergence of tokenised money — programmable, borderless, algorithmically enforced — demands a rethinking of legal categories to match. CBDCs, in her reading, recalibrate the balance between state and market, privacy and surveillance, stability and competition; and their engineering choices, from offline payments to the governance of the source code of national currencies, are legal choices in disguise.

Against this backdrop she set out the contribution of private international law: the HCCH's four pillars — jurisdiction, applicable law, recognition and enforcement, and cross-border cooperation — and the two experts groups now working at the normative level, on CBDCs and on digital tokens. Her conclusion returned to the conference's own artistic motif, "Between Light and Shadow": money, like Caravaggio's canvases, is chiaroscuro — it illuminates value and trust while casting shadows of exclusion and control — and the question is no longer whether the tokenised future will arrive, but under what rules, under whose morals, and in whose interests.