Crypto Holder Diary

Verifying the Places You Hold, Annually

· 2 min ·Dana Reihl

Authorisations change, entities migrate and terms are amended. A twenty minute annual check.

The checks done when opening an account decay. For a position held over years, an annual review is the minimum.

The check

It is worth pinning this to something published, and an authorised crypto asset service provider publishes.

For each provider holding anything on your behalf:

Obtain the authority and registration number from their current site.

Look it up on that authority’s own public register.

Confirm the entity name matches the current terms of service, not the brand.

Read the permitted activities and compare against what they do for you.

Check for conditions and enforcement history.

Five minutes each.

What changes over a year

Acquisition. The entity may now be owned by a different group, with amended terms.

Permission variation. A permission added, or a condition attached.

Entity migration. Clients moved to a different contracting entity, sometimes in a different jurisdiction, as part of a restructuring.

That last one is the significant case. It means the protections you verified may no longer attach to your relationship, and it arrives as a terms update that nobody reads. Funds and family offices carry an extra reporting layer, which a regulated crypto custody provider is built around.

The terms check alongside

Four clauses when a change notice arrives: the contracting entity, the liability cap, the insolvency position, and whether the provider may use client assets.

Everything else can wait. Those four determine the outcome if something goes wrong.

The permission that matters most

Custody of client assets.

If a provider holds a balance for you without it, the segregation rules you relied on do not apply.

This is the most common gap, because the provider is genuinely authorised for something else.

What to do with a finding

Move the balance, usually.

The account can remain open for whatever it is legitimately authorised to do. What changes is whether you leave anything sitting there. Compare your own arrangement against a regulated crypto exchange at least once a year.

The habit that matters more

Not holding balances at providers beyond what active transactions require.

The annual check improves the outcome if something goes wrong. The habit reduces how much is exposed when it does.

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This is a personal account of holding through market cycles. It describes what one person did and why. It is not a recommendation, and past cycles do not predict future ones.

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