Advised a cryptocurrency multilateral trading facility on its CASS obligations and requirements, in advance of it requesting regulatory permission to perform custody activities

The Firm was considering applying for permission to perform Custody activities and required an independent assessment of its preparedness.

We performed a review of the Firm’s preparedness for the commencement of Custody activities. We performed an end to end review of the Firm’s proposed CASS envronment. This included reviewing the mitigation of key CASS risks incuding the treatment of stock and cash, reconciliation arrangements, the arrangements for TTCA clients, contracting and the manner in which the Firm was proposing to handle money flows.

We considered the Firm’s arrangements against specific CASS requirements (including CASS 1, CASS 3, CASS 6, CASS 7 and CASS 10) as well as typical market practices when considering the Firm’s business model. We provided the client a summary report of potential or actual gaps against CASS requirements.

We provided a summary report to the client that enabled it to enhance specific systems and controls in advance of further engagement with the regulator.