Institutional Digital
Asset Custody

Bank custody infrastructure after SAB 122

How regulated banks and qualified custodians safeguard Bitcoin and digital assets for institutional clients under modern accounting, regulatory and operational frameworks.

Regulated
Custody
Segregated
Wallets
Institutional
Controls
Regulatory
Alignment
i
Post-SAB 122 Framework
SEC SAB 122 rescinded SAB 121 effective 30 January 2025. U.S. banking agencies issued joint safekeeping guidance in July 2025.
SEC
SAB 122
30 Jan 2025
OCC
OCC
Interpretive
Letter 1183
FDIC
Crypto
Activities 2025
BCBS
Basel Standard
1 Jan 2026
1. CUSTODY MARKET LANDSCAPE
Institution / Provider Type Custody Offering Jurisdiction Status
BNY Mellon
Bank Custodian Digital Asset Custody
Enterprise Wallets 		U.S. / Global Active
State Street
Bank Custodian Digital Assets Platform
Wallets & Custody 		U.S. / Global Active (2026)
Fidelity Digital Assets
Qualified Custodian Crypto Custody &
Financing 		U.S. Institutional
Coinbase Custody
Qualified Custodian Institutional Custody U.S. / Global Institutional
Anchorage Digital
Qualified Custodian Institutional Custody U.S. Institutional
Note: This is not an exhaustive list. Offerings vary by jurisdiction and client type.
2. CUSTODY ARCHITECTURE
Client
Custodian
Wallet Control
Layer
Key Management
Blockchain
Key Elements
✓ Regulated entity oversight
✓ Cold storage by default
✓ Segregated client accounts
✓ Real-time monitoring
✓ Multi-layer key controls
✓ Audit & reconciliation
As of 17 August 2026
3. CUSTODY MODELS COMPARED
Model Key Control Regulatory Structure Operational Model Typical Use Case Risk Profile
Bank Custody Custodian Regulated Bank Institutional Institutional clients, funds, corporates Low–Medium
Qualified / Specialist Custody Custodian Entity Specific Institutional Hedge funds, institutions, family offices Medium
Self-Custody Asset Owner None Inherent Direct Protocols, funds, large institutions High
Exchange Custody Platform Platform Specific Trading-Linked Retail / active trading High
4. KEY OPERATIONAL COMPONENTS
Wallet Segregation
Omnibus vs. segregated
wallets with on-chain
address separation.
Cold & Warm Storage
Majority of assets held in
air-gapped cold storage
with controlled access.
Key Management
Institutional key lifecycle,
MPC / multisig, HSMs
and backups.
Monitoring & Controls
Real-time monitoring,
withdrawal policies and
activity alerts.
Reconciliation
On-chain & off-chain
reconciliation with
independent attestations.
Insurance & Coverage
Crime, cyber and custody
insurance subject to
policy terms.
Subcustodian Oversight
Due diligence, audit rights
and ongoing risk
assessment.
As of: 17 August 2026
5. POST-SAB 122 TIMELINE
2022
SAB 121 Issued
SEC staff guidance on safeguarding crypto assets.
30 JAN 2025
SAB 122 Effective
SAB 121 rescinded. New accounting framework in place.
APR–JUN 2025
OCC & FDIC Actions
Updated statements on permissible activities and custody.
JUL 2025
Joint Safekeeping Guidance
U.S. banking agencies issued risk-management considerations.
2026+
Institutional Implementation
Banks and custodians scale institutional offerings.
As of: 17 August 2026
Institutional Digital Asset Custody
CUSTODY SPOTLIGHT
Banks Expanding Institutional
Digital Asset Custody
Global systemically important banks are investing in custody infrastructure, wallet management and digital asset platforms to meet growing institutional demand.
VIEW CUSTODY LANDSCAPE REPORT →
Understand custody risk, architecture and regulation in depth.
Access the 2026 Commercial Banking & Digital Asset Custody Report.
ACCESS THE 2026 REPORT →

Actionable intelligence on how commercial banks integrate Bitcoin and digital assets into custody, execution, lending and settlement infrastructure.

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