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Institutional custody due diligence under MiCA

For an entity authorised as a crypto-asset service provider in Spain: choosing a custody vendor on evidence, testing it in production and taking the decision to management.

Role: Product and operations consultant
Period: 2026 – now
Sector: Institutional crypto-asset custody · regulated entity (confidential client)

8weighted decision criteria

7ecosystems tested in production

26pages of decision report for management

The challenge

The entity had to decide whether to change custodians: the current one had gaps and the candidate was untested. The decision had to withstand review by security, management and the supervisor.

What I did

Eight weighted decision criteria, a custom test protocol and a coverage matrix across about 40 networks.
An end-to-end proof of concept on a production environment: deposit, custody and withdrawal on Bitcoin, EVM L1/L2, Solana, Tron, Hedera, Cardano and Polkadot, NFTs included.
Structured vendor questionnaires and an analysis of the MiCA fit: reporting obligations, DTI identifiers, deposit traceability and an exportable audit log.
15+ guides and procedures so non-technical teams can run custody operations.

Images

Real case The case in numbers. The client and the vendors evaluated are confidential.

Interface concept My own operations panel concept: deposits per network with origin, Travel Rule and screening. Not the client's system.

Interface concept Concept: a chained audit log, exportable for the supervisor.

What I take away

In a regulated decision, what convinces is not the conclusion but the evidence behind each claim: that is why every point in the report states where it comes from.

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