Compliance · Jul 30, 2026 · 9 min read
A custody checklist for your first license application
The technical controls regulators consistently ask about, grouped so your team can prepare in parallel.
Regulators across the region phrase their rules differently, but the questions about custody converge on a handful of themes: key management, segregation, access control, incident response and auditability.
Key management: document how keys are generated, where they live, who can use them, and how you'd recover if a site went dark.
Segregation: show that client assets are separated from house assets on-chain and in your books, and that reconciliation happens daily.
Access and audit: prove that no single person can move funds, and that every action leaves a tamper-evident record.