I remember the first time I had to brief a board about our company’s nascent Bitcoin and Ether treasury. The questions were sharp: How do you secure these assets? Who signs transactions? What happens if a private key is lost? Over the years I’ve helped craft treasury controls across several organisations, and I want to share a precise, practical playbook that a CFO can implement immediately to protect corporate BTC and ETH holdings.
I’ll speak from experience and name specific tools where they make sense. You can adapt the controls to your company size and risk appetite, but the core principles—separation of duties, layered defenses, transparency, and tested recovery—remain universal.
Establish a formal crypto treasury policy
Before any technical control, create a written crypto treasury policy. This document should define:
Make this document an internal policy with board sign-off and periodic reviews (quarterly at minimum).
Choose custody model and vendors carefully
Your custody decision is one of the highest-impact choices. Options include:
Consider these criteria: insurance coverage, SOC 2/ISO certifications, regulatory posture, geographic jurisdiction, SLAs for withdrawals, and integration with your treasury systems. For many CFOs, an institutional custodian combined with a separate recovery cold storage gives strong security and operational simplicity.
Implement multi-layered key management
Never rely on a single private key. Use one or more of the following approaches:
Design your scheme so that a single compromised person or device cannot move funds.
Enforce strict role-based access and separation of duties
Roles should be clear and limited:
Implement RBAC in custody provider dashboards and internal systems, require MFA, and limit admin rights to very few people.
Transaction approval workflows and limits
Define thresholds and workflows:
Use pre-signed templates, whitelisting of destination addresses, and time-locked transactions for large or unusual moves.
Use whitelisting, time-locks and delays
Whitelisting destination addresses significantly reduces risk from phishing or credential compromise. Combination controls I recommend:
Monitoring, reconciliation, and real-time controls
Maintain transparency and rapid detection:
Reconciliation should include provenance checks—confirm that tokens are where they should be and linked to approved addresses.
Accounting, auditing, and reporting
Integrate crypto holdings into financial reporting. Controls include:
Insurance, legal, and compliance
Purchase institutional crypto insurance if available. Confirm the policy covers third-party custodian failures, staking operations, and theft from credentials. Legal and compliance workstreams should:
Incident response and disaster recovery
Design and test an incident response plan that covers loss, compromise, or insolvency of a custodian. Elements:
I’ve seen companies skip tests—and when something goes wrong, they discover missing steps at the worst time. Test often.
Periodic key rotation and backup controls
Rotate keys on a schedule and after any personnel change. Backups of recovery seeds or HSM backups must be split, encrypted, and stored in geographically separate vaults with dual-control access (e.g., two custodians must be present to retrieve).
Metrics and KPIs for the treasury desk
| Control | Purpose | Owner |
| Daily reconciliation | Ensure on-chain and accounting parity | Treasury/Accounting |
| Whitelisted addresses | Prevent unauthorized withdrawals | Security/Treasury |
| Transaction time-locks | Detection window for fraudulent moves | CFO/Treasury |
| Insurance coverage | Transfer some financial risk | Legal/CFO |
Track KPIs such as time-to-detect anomalies, time-to-approve routine transactions, and % of assets in cold vs hot storage. These metrics drive governance decisions.
Finally, remember this is about people and process as much as technology. Invest in training, clear documentation, and an organisational culture that treats crypto as a first-class financial asset. The tools—Gnosis Safe, Fireblocks, BitGo, Coinbase Custody, Ledger HSMs—are important, but they only work when embedded in disciplined policies and tested operational routines.