Custody policy and AML/KYC framework for a digital asset custodian
An institutional custody policy and AML/KYC/CFT addendum for a Fireblocks-based custody and settlement setup, written to be handed to a regulator.
- Client
- UK-based digital asset custodian (confidential)
- Service
- Strategy and research
- Period
- Oct–Nov 2024
- Review
- 5.0 on Upwork
Client documents
Confidential. Not published here; available to prospective clients under NDA.
- NDADigital asset custody policy
- NDAAML/KYC/CFT addendum
Ask for samples and say which engagement you're interested in.
The brief
The client ran custody and settlement on Fireblocks with Kraken fiat rails and needed documentation that would hold up to regulatory review: how keys are controlled, how wallets are screened, and how every movement is reconciled. The policy was mapped to FCA CASS segregation rules, the FATF Travel Rule and FinCEN guidance.
What I did
- Segregated hot and cold wallet structure on Fireblocks with client-specific MPC key control
- Travel Rule enforcement using Chainalysis KYT and Notabene for transaction monitoring and VASP data exchange
- SOPs for beneficial-owner screening, high-risk wallet tagging and enhanced due diligence
- Daily internal and external reconciliation across Fireblocks, Kraken and on-chain explorers
- More than 20 automated red-flag rules across wallet traffic, with high-risk wallets locked automatically
Frameworks and tools
- Fireblocks
- Kraken
- Chainalysis KYT and Reactor
- Notabene
- FCA CASS 7
- FATF Travel Rule
Outcome
- Audit-ready documentation with daily reconciliations and wallet audit trails
- A modular pack for regulator-facing submissions, since reused across the client’s wider compliance stack
Client feedback singled out the structure, the clarity and how closely the documents matched what regulators expect.
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