Custody arrangement review: documents to prepare
A custody arrangement review checks who actually controls the private keys, wallets or accounts holding a token issuer's assets, and whether the paperwork matches that control. Prepare custodian agreements, wallet inventories, signing-authority records and any sub-custody chain before the review starts. Missing documents are the main reason reviews stall.
What changes once the review starts
Once a custody arrangement review is under way, the custodian and the issuer both become subject to document requests that carry short deadlines. A request left unanswered for more than a few working days tends to widen, not narrow, because the reviewer has to ask again with more precision. The practical effect is timing risk: a token launch or a supply change that depends on custody sign-off can slip by weeks if the underlying paperwork is incomplete at the outset.
The review does not decide whether the custody arrangement is commercially sound. It checks whether the documents describe the arrangement accurately and consistently. That distinction matters when instructing counsel or a custodian's compliance team, because it sets the boundary of what the review can and cannot tell you.
What to prepare
- Issuer: collect the current custody agreement, any amendments, and the schedule of assets covered.
- Issuer: list every wallet address and account in scope, with the entity that controls each one.
- Custodian: produce the signing-authority matrix showing who can move assets and under what approval threshold.
- Custodian: confirm whether any sub-custodian is involved and supply that sub-custody agreement separately.
- Both sides: agree who keeps the working copy of each document during the review and who holds the reference copy afterwards.
Point five is where most delays start. A review cannot progress on the basis of a document that one side has amended after sending it. If retention of the reviewed copy matters to you, our note on Retention: the report, the extracts and our copy explained sets out how the report, the extracts and the working file relate to each other once the review closes.
Who decides, and by when
The custody arrangement review is not adjudicated by a court or regulator in the ordinary case. It is a bilateral check between the issuer's advisers and the custodian's compliance function, closed by a written sign-off or a written list of open points. Where the custodian sits under supervision, its own compliance officer signs off internally before the external sign-off is issued. Typical turnaround for a single custodian with a clean document set is two to three weeks from the first complete document package.
| Stage | What is produced | Typical timing |
|---|---|---|
| Document collection | Custody agreement, wallet inventory, signing matrix | 3–10 working days |
| Gap list | Written list of missing or inconsistent items | 3–5 working days after collection |
| Follow-up round | Corrected or supplementary documents | 5–10 working days, repeatable |
| Sign-off or open-points memo | Written closure of the review | 2–5 working days after the last follow-up |
Two common forks
If the custodian is regulated in more than one jurisdiction, the review has to reconcile the signing-authority matrix against each local licence, and the follow-up round usually runs twice. If the custodian is new to the issuer and no prior review exists, expect the collection stage to take the full ten working days, because wallet inventories are rarely maintained in review-ready form from day one.
If the sub-custodian refuses to share its own agreement directly, the review can still proceed on the primary custodian's representation, but the sign-off will note that the sub-custody layer was not independently verified. That gap should be recorded in writing, not left implicit.
Where a document request goes unanswered
A custodian or sub-custodian that does not respond to a document request within the agreed window does not stop the review by silence. The reviewer records the request as outstanding, notes it in the gap list, and the sign-off is issued with that item flagged as open. This keeps the file honest without forcing an artificial deadline on a party that is not under the issuer's control.
Sources and limit
This page describes the review procedure and the documents it requires; it does not verify the custodian's regulatory standing, the counterparty behind the arrangement, or the jurisdiction where a sub-custodian is licensed. Those checks sit in our reports layer. Where the custodian is based in the United Kingdom, the starting point is our Counterparty in United Kingdom report, which sets out what can be established about a UK counterparty and what cannot.
Where a specific document needs independent authentication rather than a procedural check, our Document in Austria report explains the scope of a document check under Austrian sources. Where the open question is which jurisdiction's rules apply to a sub-custody chain, our Jurisdiction in Italy report sets out what an Italian jurisdiction check can and cannot confirm.
None of these reports replace the custody arrangement review itself. They answer a narrower factual question that the review may surface but cannot resolve on its own.
Related publications
A supply change on an already-issued token follows a related but distinct document trail. See Supply change procedure step by step for the documents that apply once tokens are already in circulation.
FAQ
How long does custody arrangement review take in practice? With a complete document package from the outset, two to three weeks is typical. Missing or inconsistent documents add a follow-up round of five to ten working days, and this can repeat more than once.
Which documents are needed to start? The custody agreement and its amendments, a full wallet or account inventory, the signing-authority matrix, and any sub-custody agreement. A review cannot start meaningfully without all four.
What happens if the other side does not respond? The outstanding request is recorded in the gap list, and the review closes with that item flagged as open rather than waiting indefinitely. This keeps the timeline moving without pretending the gap does not exist.
Reviewed
This page was checked against current internal procedure notes at the time of publication. The documents it references are custody agreements, wallet inventories and signing-authority matrices supplied by the parties; these are not public registers and are not cited by number or article. Where a specific counterparty, document or jurisdiction needs independent confirmation, the reports layer linked above is the appropriate next step, not this page.