Choose a stablecoin custodian by first confirming that the specific legal entity is eligible to provide the specific service in your jurisdiction, then testing whether its asset controls, safeguarding arrangements, operations and contract fit your institution’s needs. A bank charter, a license for another entity or activity, or a security claim alone does not establish that a provider is suitable.
What should your institution define before evaluating custodians?
Set the scope before inviting proposals. A custodian’s suitability depends on what your institution will hold and do, where it operates, and which legal entity provides the service. Record:
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- Your role: whether you are holding stablecoins for your own account, safeguarding them for clients, or performing another activity.
- Jurisdictions: where your institution and relevant customers are located, and where the contracting and custody entities operate.
- Assets and networks: the stablecoins and blockchain networks you need to support.
- Use cases and flows: expected deposits, transfers, settlement, redemption, approval requirements and reporting needs.
- Risk constraints: internal limits, control requirements, resilience expectations and tolerance for reliance on subcontractors.
These details let procurement, legal, risk and technology teams assess the same service rather than compare providers on broad marketing descriptions.
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Verify the exact entity that will sign the contract, the regulator supervising it, the permission it holds, and whether that permission covers the proposed activity, asset, client type and geography. Ask the provider to identify the applicable authorization and explain any reliance on an affiliate or subcontractor. Check the relevant regulator’s current records and obtain legal advice for the institution’s circumstances.
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Distinguish binding requirements from proposals, guidance and policy analysis. Regulatory frameworks differ across jurisdictions and can change; a provider’s authorization for one service or entity should not be treated as authorization for another.
United States: distinguish the FDIC proposal from existing expectations
An FDIC proposal dated April 2026 would establish requirements for FDIC-supervised permitted payment stablecoin issuers and certain insured depository institutions providing related custody and safekeeping. The proposed provisions address 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. The proposal also describes limited exceptions, including identifiable omnibus accounts for specified insured institutions. These are proposed provisions, not a statement that the proposal is already binding law. Confirm its status and the rules applicable to the particular institution and service.
Separately, a July 14, 2025 joint statement from the Federal Reserve, FDIC and OCC says existing risk-management principles apply to bank crypto-asset safekeeping and that such activity must be conducted safely and soundly and in compliance with applicable laws and regulations. The Federal Reserve release says of the statement: “The statement does not create any new supervisory expectations.” That statement is not a vendor certification or a substitute for checking the institution’s specific obligations.
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United Kingdom: check the activity and applicable dates
The FCA’s CP25/14 page records final rules and guidance published on June 30, 2026, and says they will apply to cryptoasset firms authorized under FSMA on or after October 25, 2027. For a particular provider, establish which activity and entity are covered and whether transitional arrangements affect its position. Check current FCA materials rather than assuming the future application date means every firm is already subject to the same requirements.
The Bank of England’s June 2026 paper sets out an 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 custody as making stablecoin holdings equivalent to insured bank deposits; analyze the issuer’s obligations and the custody arrangement separately.
Use international analysis as context, not as law
The BIS Financial Stability Institute’s August 2026 overview describes differences in regulatory approaches, including which entities may issue stablecoins and restrictions on activities beyond issuance, redemption and reserve management. It notes that lending, staking and custody can alter an entity’s risk profile. The authors say their views do not necessarily reflect the BIS, its members or Basel-based standard-setting bodies, so use the overview for comparative context rather than as binding rules.
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How can you test control, segregation and insolvency treatment?
Ask for a clear account of the legal and technical arrangements for the assets, not just a description of the custody technology. The institution should understand who can move the assets, how records identify ownership, and what would happen if a custody provider or sub-custodian failed.
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- Key and transfer control: Who possesses or controls private keys? Who can initiate and approve a transfer? What approval thresholds, segregation of duties and emergency controls apply? Can an employee, customer, affiliate or sub-custodian move assets outside the defined approval process?
- Ownership and records: How are customer assets titled and recorded? Are records sufficient to identify each customer’s beneficial interest if an omnibus account is used?
- Use of assets: Can customer assets be lent, pledged, reused or applied to fees? Require the contract and operating documents to state the answer clearly.
- Insolvency: What is the claimed treatment of assets if the custodian or a sub-custodian becomes insolvent? Which legal arrangements support that treatment, and what could creditors claim?
- Exceptions: If the provider relies on an exception to a segregation or account structure requirement, identify the legal basis and the safeguards that apply.
Do not assume that a proposed regulatory safeguard determines the result in your institution’s case. Applicable law, account structure and contract terms matter; have counsel assess them for the relevant jurisdictions and parties.
How should you assess sub-custodians and other dependencies?
Map the full custody chain. Request the names of the entities involved, their jurisdictions, the assets or functions each handles, and how the primary custodian supervises them. The contract and supporting materials should explain monitoring, audit access, incident notification, escalation and exit rights. Identify material infrastructure providers too, so the institution can assess operational dependencies rather than treating the named contracting party as the whole service.
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The FDIC proposal describes sub-custody in specified circumstances with oversight safeguards. That proposal is not proof that a particular provider’s chain meets those safeguards or that the same legal framework applies elsewhere. Verify the actual arrangement and the rules relevant to it.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What operational and security evidence should you request?
Evaluate how the service works under normal conditions and when something goes wrong. General regulatory statements do not certify a vendor’s performance, so request provider-specific evidence and test the relevant workflows before relying on them.
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- Approvals and transfers: transaction approval paths, limits, segregation of duties, exception handling and emergency procedures.
- Recovery and continuity: recovery arrangements, tested recovery objectives, business continuity procedures and escalation paths.
- Incident response: how the custodian detects, reports and responds to security or operational incidents, and what notice the institution receives.
- Reconciliation and reporting: how holdings and transactions are reconciled, what records are available, and how often reporting is delivered.
- Asset and network support: which stablecoins, networks, transaction types and settlement windows are supported, including any restrictions relevant to the institution’s planned use.
- Redemption and integration: how redemption workflows operate and how custody connects with the institution’s systems and controls.
Ask which evidence is independently assured, what period and scope it covers, and whether it applies to the contracting entity and service under consideration. A security tool or assurance document is evidence to evaluate, not a conclusion about legal control, segregation or suitability.
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How do you compare providers and make a decision?
Use legal eligibility and asset protection as threshold tests. Eliminate a provider if it cannot establish that the right entity may provide the required service or if material questions about control, segregation or insolvency remain unresolved. Among providers that pass those gates, compare the remaining factors against your transaction flows, control capacity and risk appetite.
| Decision area | Evidence to obtain | Decision question |
|---|---|---|
| Eligibility | Contracting entity, regulator, permission and service scope | Does this entity have the required status for this activity, client type and jurisdiction? |
| Control | Key governance, transfer approvals, access controls and emergency procedures | Can assets move only through an approval process the institution understands and accepts? |
| Safeguarding | Account title, ownership records, segregation, permitted use and insolvency analysis | Are legal rights and records clear enough for the institution’s risk requirements? |
| Dependencies | Sub-custodian and service-provider map, oversight, audit and incident terms | Can the institution monitor and manage the entire custody chain? |
| Security and resilience | Provider-specific control evidence, recovery testing and response procedures | Can the service meet operational and recovery needs under realistic scenarios? |
| Operational fit | Supported assets and networks, workflows, reconciliation and reporting | Does the service fit the institution’s actual transaction and oversight processes? |
| Contract and economics | Service levels, liability limits, indemnities, fees, termination, migration and dispute terms | Are the obligations, remedies and exit costs acceptable? |
Regulatory sources do not establish a particular provider’s service levels, pricing, liability allocation or performance. Verify these in the provider’s contract and supporting documentation. Before approval, document unresolved risks, owners and mitigations; set ongoing review triggers for changes to authorization, supported assets, custody-chain participants, contract terms or applicable rules.
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