Custody is the question on which most digital-asset businesses either succeed or quietly fail. Who holds the keys, under what legal arrangement, with what separation from the firm’s own assets, and what happens if the firm becomes insolvent — these are the questions a bank, a regulator and an institutional client all ask, and they rarely get a good answer.
We design the custody model, then paper the legal basis for it. Self-custody with multi-party computation, qualified third-party custody, sub-custody arrangements and hybrid models each carry different regulatory, insolvency and insurance consequences, and the choice should follow from the customers you serve.
Alongside custody we design the transaction flows — deposits, withdrawals, on-ramp and off-ramp — because that is where the licensing perimeter and the compliance risk actually live.
- You hold client assets and cannot clearly explain the legal basis on which you hold them.
- A bank, exchange or institutional client has questioned your custody arrangements.
- You are choosing between self-custody, third-party custody and a hybrid model.
- Your deposit, withdrawal or on-ramp flows may be regulated activities you have not identified.
Legal separation is the core
If client assets are not legally segregated from the firm’s estate, custody is a promise rather than a protection — and the licensing and banking consequences are severe.
Key management is a control, not a technology
Multi-signature, MPC and hardware-module choices are business controls with governance implications, not merely engineering preferences.
The perimeter lives in the flows
Whether you are transmitting, safeguarding or exchanging is determined by what happens between deposit and withdrawal, and that is where authorisation requirements appear.
- Custody-model options analysis against your customer base and licence
- Legal basis and segregation documentation for client assets
- Key-management, multi-signature and control design
- Deposit, withdrawal and on/off-ramp flow architecture
- Perimeter analysis for each flow and the authorisation it requires
- Custodian selection and due-diligence support where third-party custody is used
- 01
Map who holds what
Every point at which assets or keys are controlled, and by whom, because the custody analysis is derived from that map.
- 02
Choose the model
Self, third-party or hybrid custody, selected against the customers you serve and the licence you hold or need.
- 03
Document the basis
Segregation, insolvency treatment and client-asset protection written so a bank, auditor or regulator can rely on it.
- 04
Design the flows
Deposit, withdrawal and on/off-ramp mechanics, with the regulated step at each point identified.
- 05
Select and integrate
Custodian and technology selection, due diligence and support through integration and first live transactions.
Custody model review
A written assessment of your custody arrangements, the legal basis and the exposure if they are not documented.
Custody and flows programme
Model design, legal documentation and flow architecture delivered through to implementation.
Custodian selection support
Shortlisting, due diligence and negotiation support for a third-party custody arrangement.
- Firms intending to hold client assets without a legal basis for doing so, which is a solvency and licensing problem waiting to happen.
- Businesses that treat custody as an engineering detail rather than a legal and governance question.
Both are viable, and the right answer depends on your customers and your licence. Institutional clients often expect a qualified custodian; retail platforms frequently self-custody with strong controls. What matters is that whichever model you use has a documented legal basis and segregation of client assets.
Both distribute control so no single key holder can move funds alone. MPC splits a single key into shares used in computation; multi-signature requires several distinct keys to authorise a transaction. The choice affects operational resilience, recovery and auditability, and we advise on it as a governance decision.
Possibly, depending on the jurisdiction and whether you are merely facilitating a transfer or operating a payment service. This is exactly the sort of question that gets answered late and expensively, so we map each flow against the regimes in your markets before launch.
By structuring so that client assets are legally separate and not part of the insolvency estate — typically through segregation with a qualified custodian or a trust arrangement. Where that separation does not exist, clients rank as unsecured creditors, which is both a regulatory and a reputational catastrophe.