Holding client assets is one of the most sensitive parts of any model. We determine the legal status of custody and prepare the procedures and the technical perimeter.
Who controls the keys: the company, the client or an external provider
Is custody a standalone service or part of exchange, trading or a platform
How client assets are segregated from the company's assets
What the recovery, signing and access control procedures are
Who is liable in case of loss or compromise
Which information security and reporting requirements apply
How an activity is classified depends on the actual model: who is the client's counterparty, where assets and keys are held, how settlement works, who the services are for. Information is current as of October 2026 and is confirmed during the project assessment.
Custody status and requirements defined
Model chosen: in-house, external or mixed custody
Policies, contracts, access procedures
Wallets, roles, reconciliations, monitoring
Custody reflected in the core licence or registration application
Access reviews, procedure updates
The sequence depends on the regime. Some work runs in parallel, but regulated activity starts only after the required permits are obtained.
Separately: custody model classification, asset segregation policy, key procedures, provider selection, technical architecture.
Full scope: custody is built into the overall exchange, trading or platform model and runs through all documents and systems.
Turnkey launchCost and timing are set after the project assessment.
Describe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.
Discuss your projectUnder the national regime the question is answered by analysing the core model and the statuses provided by law. We give our view after assessing the specific structure.
Often yes, but liability to clients and the regulator stays with the company. The agreement and provider oversight procedures must reflect this.
We will review the description and give you a substantive reply: which regime may apply and where to start.
Powered by Paralex