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Scan for outdated or missing drivers - takes under a minuteDriver Scan →Repair Windows errors before they cause bigger problemsFix Now →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →Choose a stablecoin custodian only after confirming that the exact contracting entity is eligible to provide the specific service in your jurisdiction. Then establish who controls the assets and keys, what happens if the custodian or a sub-custodian fails, and whether the provider’s controls and operating processes fit your institution’s transaction flows. A bank charter, a license for another entity or activity, or a security product by itself does not establish that a custody arrangement is suitable.
The US and UK regulatory materials discussed below have different scopes and legal status. They are useful context, not a substitute for checking the rules, permissions, contracts and supervisory position that apply to your institution and provider.
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Start by defining the custody need
Before contacting providers, specify what your institution intends to hold and do. Custody requirements can differ depending on whether the institution holds stablecoins for its own account or for clients, which stablecoins and networks are involved, and whether the service includes transfers, redemption support, or other activities.
- Identify the institution’s legal entity, the jurisdictions where it operates and serves customers, and whether the assets are proprietary or held for clients.
- List each stablecoin, blockchain network, transaction type, settlement window and expected transfer-approval path.
- Separate custody and safekeeping from issuance, redemption, reserve management, lending, staking or other services. Activities beyond issuance, redemption and reserve management can change an entity’s risk profile, according to an August 2026 overview by the BIS Financial Stability Institute. The authors note that their views do not necessarily represent the BIS, its members or Basel-based standard-setting bodies; treat the overview as comparative context, not binding law.
This scope becomes the test for a provider’s permissions, controls, supported workflows and contract. A general statement that a firm offers “digital-asset custody” does not answer whether its specific entity can provide the particular service to your institution.
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Use a threshold-and-fit framework
First resolve legal eligibility and the legal treatment of customer assets. Do not offset uncertainty on either point with a high score for technology or convenience. Once those thresholds are met, compare providers against your institution’s operational requirements and risk appetite.
| Assessment area | Questions to resolve |
|---|---|
| Legal eligibility | Which legal entity signs? Which regulator supervises it? Does its permission cover this activity, asset, customer type and jurisdiction? Are relevant rules final, proposed or not yet effective? |
| Asset and key control | Who possesses or controls the keys? Who can initiate and approve a transfer? What prevents unilateral movement outside the defined approval process? |
| Safeguarding and insolvency | How are assets titled, recorded and segregated? Are omnibus accounts used? May customer assets be lent, pledged, reused or applied to fees? What treatment applies if the custodian or a sub-custodian becomes insolvent? |
| Sub-custody and dependencies | Which entities and service providers participate, where are they located, and what oversight, incident-notice and exit rights does the primary custodian provide? |
| Security and resilience | What evidence supports access controls, key management, recovery, continuity and incident response? What recovery objectives have been tested, and who is notified when an incident occurs? |
| Operational fit | Which assets, networks and transaction types are supported? How do approvals, settlement, redemption, reconciliation, reporting and integration work? |
| Contract and economics | What service levels, liability limits, indemnities, fees, termination and migration rights, and dispute forum apply? |
These are questions for provider-specific diligence, not claims that any particular custodian has passed them. Ask for evidence tied to the contracting entity and the service under consideration.
Verify the entity’s authorization and regulatory scope
Check the provider, not just its brand
Obtain the full legal name of the entity that will contract with your institution and perform each part of the service. Confirm the relevant regulator, permission and activity against current official materials. Match the permission to your institution’s location, customer type, assets and intended use; authorization of an affiliate or for a different activity is not enough.
Record which requirements are binding now, which are proposed, and which have a future application date. Regulatory status and implementation timelines can change, so confirm them at the time of selection and again before onboarding or material changes to the service.
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United States: distinguish existing supervisory guidance from a proposal
A July 14, 2025 joint statement by the Federal Reserve, FDIC and OCC says existing risk-management principles apply to bank crypto-asset safekeeping and reminds banks to conduct it safely and soundly and in compliance with applicable law and regulation. The Federal Reserve’s release describing the statement says, “The statement does not create any new supervisory expectations.” That statement is not a certification of any provider or its performance.
An FDIC proposal from April 2026 would establish requirements for FDIC-supervised permitted payment stablecoin issuers and certain insured depository institutions providing related custody and safekeeping. The proposed text addresses possession or control of customer property; written policies and internal controls; technical safeguards against unauthorized employee access; separate accounting and segregation; and oversight of sub-custodians. It also describes limited exceptions, including identifiable omnibus accounts for specified insured institutions. These are proposed provisions in the material described here, not a statement of final requirements. Check subsequent rulemaking and the institution’s actual regulator before relying on them.
United Kingdom: check the activity and transition date
The FCA’s CP25/14 page records final rules and guidance published on June 30, 2026, and states that they will apply to cryptoasset firms authorized under the Financial Services and Markets Act (FSMA) on or after October 25, 2027. For a particular provider, verify the precise activity covered, its entity’s status, any transitional position and the FCA’s current materials; the publication and application dates do not establish that every custodian is authorized or covered in the same way.
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The Bank of England’s June 2026 paper sets out its approach for sterling-denominated systemic stablecoins. It discusses legal claims and redemption rights, redemption timelines, safeguarding, custody rights, backing assets, capital and failure management. It states that coinholder claims under that framework are not insured by the Financial Services Compensation Scheme (FSCS). Do not treat stablecoin holdings as equivalent to insured bank deposits on the basis of an ordinary custody arrangement.
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Establish who controls assets and keys
Map the authority to move assets from instruction through final approval and execution. A provider’s description of its key technology does not establish which people or entities can cause a transfer, whether customer assets can be moved outside agreed approvals, or what happens during an emergency.
- Ask who possesses or controls private keys, including any provider personnel, affiliates or sub-custodians.
- Trace who can initiate, approve, block and release a transfer. Identify approval thresholds, segregation of duties and emergency access.
- Ask what technical and contractual controls prevent unauthorized employee access and prevent one party from moving assets unilaterally.
- Confirm whether a customer, affiliate or sub-custodian can move assets outside the institution’s documented approval process.
- Request evidence of how access changes, exceptions and attempted unauthorized actions are recorded and escalated.
Compare the documented control model with the institution’s own authorization policy. Resolve any gap before assets are transferred to the service.
Read safeguarding and insolvency terms together
Ask legal and risk teams to examine the account structure, asset records and contract as one arrangement. The essential issue is how the institution’s rights to the assets would be established and treated if either the primary custodian or a sub-custodian failed—not simply whether the provider uses the word “segregated.”
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- Confirm account title, the identity of the beneficial owner recorded, and how balances are attributed to the institution or its clients.
- Determine whether the provider uses omnibus accounts and, if so, how individual interests are identified and reconciled.
- Review whether the custodian may lend, pledge, reuse or otherwise encumber assets, or apply them to fees or other obligations.
- Trace the custody chain to determine which entity holds assets at each stage and what rights apply at each level.
- Review the contract and applicable law for the stated treatment of assets in custodian and sub-custodian insolvency.
Do not infer the outcome for your institution from regulatory proposals or general descriptions of safeguarding. Applicable law and the executed contract govern the specific arrangement.
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Map sub-custodians and operational dependencies
Request a complete map of entities and infrastructure providers involved in custody, including each party’s role and jurisdiction. Ask how the primary custodian selects and monitors sub-custodians, what audit or information access is available, how incidents are escalated, and what rights the institution has to exit or move assets if a dependency changes.
The April 2026 FDIC proposal described above contemplates sub-custody in specified circumstances with oversight safeguards; it does not establish that a particular provider’s chain is acceptable or compliant. Assess the actual chain and its contractual oversight rather than relying on a high-level assurance.
Test whether the service fits daily operations
Use representative workflows, not a list of supported features, to evaluate the provider. Confirm support for every required stablecoin and network, then walk through the institution’s transaction and reconciliation processes with the teams that will operate them.
- Trace how a transaction is requested, checked, approved, settled and reported, including exception handling.
- Establish which settlement windows, transaction types and redemption-related workflows are supported, and which depend on another party.
- Check how balances and transactions are reconciled against the institution’s records, how discrepancies are investigated, and what reporting is available.
- Evaluate integration with the institution’s existing systems and controls, including change management and access administration.
- Review business-continuity and recovery arrangements, incident response responsibilities, escalation paths and tested recovery objectives.
Obtain provider-specific evidence and put required service levels and incident obligations in the contract. General statements by regulators about risk management do not establish a vendor’s service quality or resilience.
Negotiate remedies, migration and accountability
Have legal, procurement, compliance, technology and operations teams review the same service description and contract. Confirm that the contract covers the custody arrangement actually assessed, including any subcontracting and the allocation of responsibilities across the chain.
- Align service levels with the workflows and response times the institution needs.
- Understand liability limits, indemnities and exclusions, and how they interact with custody, security incidents and subcontractors.
- Set incident-notification, records-access and cooperation obligations that support investigation and regulatory response.
- Confirm termination rights, transition assistance and practical migration arrangements, including how assets and records are returned or transferred.
- Review pricing, fee application, governing terms and dispute forum against the proposed service and the institution’s risk tolerance.
These commercial and contractual points are not established by the cited regulatory materials; verify them in the provider’s actual documents rather than assuming that a regulatory permission supplies them.
Make the selection decision in sequence
- Define the use case. Document the institution, jurisdictions, assets, networks, customer type and intended activities.
- Screen for eligibility. Confirm the contracting entity, applicable regulator and permission for the exact service and customer context.
- Resolve asset rights. Establish control, segregation, permitted uses, custody-chain structure and insolvency treatment.
- Validate controls and operations. Review evidence for security, recovery, approvals, reconciliation, reporting and incident handling against representative workflows.
- Set contractual protections. Agree accountability, service levels, remedies, incident duties and a workable exit and migration path.
- Document residual risk. Record unresolved legal or operational issues, accountable owners and the institution’s decision to accept or reject them.
A provider should not pass the selection process solely because it is a bank, uses a hardware security module, publishes an attestation, or holds a license for a different entity or service. The decision should rest on verified eligibility, demonstrable asset protections and a contract and operating model suited to the institution’s actual use.
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