Enterprise Blockchain Consulting Solutions for Tokenization: Governance, Custody, and Controls

Summary: In the world of tokenization projects, it's all about governance, custody, and controls--way more than just the code. This guide dives into the important regulatory changes hitting us in 2025, plus design patterns that really deliver results and architectures that have proven themselves in real scenarios. And the best part? You can start putting these strategies into action within the next 90 days!

Why this matters in 2025

Tokenization has really taken off lately, going from just a cool idea to something that's actually making waves in the real world. We’re now seeing money-market fund shares being used as collateral on serious bank-grade networks, tokenized Treasuries pulling in billions, and transfer agents seamlessly pushing fund data straight onto the blockchain. But here’s the kicker: the real champions aren’t just dabbling “on-chain.” They’re designed to be compliant from day one, featuring operational resilience, trustworthy custody options, and policy-as-code. (blockworks.co)

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Executive brief: regulatory shifts that should change your architecture

• EU MiCA: So, the rules around stablecoin titles (ART/EMT) officially took effect on June 30, 2024. Then, come December 30, 2024, the full CASP obligations along with the EU “Travel Rule” (Reg. 2023/1113) are set to kick in. Just a heads-up, some member states are extending their transitional "grandfathering" periods all the way into 2026. As we move into early 2025, ESMA is pushing national competent authorities (NCAs) to crack down on non-MiCA stablecoins. It’s super important to have your authorization, custody segregation, sub-custody limits, and Travel Rule messaging all lined up right from the start. Check out more details here: (dotfile.com)
• EU DORA: Save the date--January 17, 2025! That’s when financial organizations and key ICT providers will need to start following some new standardized operational-resilience rules. And then, keep an eye on November 2025, as that’s when the EU plans to tag major cloud and data providers as “critical.” This is a heads-up that they’ll face a whole lot more scrutiny. Also, remember to factor in your custody and tokenization setup as part of the ICT landscape. Make sure you’re on top of things like incident reporting APIs, resilience testing, and ensuring that your contracts with third parties are rock-solid. (alston.com)
• U.S. accounting and banking: Exciting update! On January 23, 2025, the SEC made a big move by replacing SAB 121 with SAB 122. This means you don’t have to worry about listing custodied crypto as a liability anymore! Plus, the OCC has given the thumbs up to national banks, allowing them to offer crypto custody and tokenization support without needing a prior “non-objection,” as long as they maintain proper safety and soundness controls. This really opens up new avenues for banks to dive into tokenization and custody options. (Check it out on sec.gov)
• Basel and disclosures: Come January 1, 2026, banks are going to have to open up about their crypto holdings in a standardized way. The treatment of stablecoins will follow the Group 1b guidelines. So, it's a good idea to start prepping your plan identifiers, risk buckets, and data lineage now! (bis.org)

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What “good” looks like: a governance-custody-controls blueprint

1) Governance: permissioning, identity, and policy-as-code

Breaking Down "Governance" into Three On-Chain Capabilities

When we dive into the idea of "governance" in blockchain, it helps to break it down into three main capabilities that are super important. Here’s the lowdown:

1. Decision-Making
   At the heart of governance, it’s all about making choices that impact the entire ecosystem. This means figuring out who gets to call the shots, how those decisions come about, and making sure every voice counts. Think of it like planning a potluck dinner--everyone deserves a say in what goes on the menu!
2. Rules Enforcement
   Setting rules is just the start; enforcing them is where it gets real. This is the part that makes sure everyone sticks to the game plan. You might have automatic smart contracts that spring into action when specific conditions are met, keeping the playing field level. It’s like having a referee in a match, ensuring that everything runs smoothly and fairly.
3. Transparency and Accountability
   Trust in governance really hinges on transparency. This feature makes sure that every decision and transaction is out in the open, all neatly recorded on the blockchain. It keeps individuals and organizations accountable for what they do. Imagine it like an open diary where everyone can peek in and see what's happening--no secrets allowed!

Breaking governance down into these three on-chain capabilities helps us get a clearer picture of how decentralized systems function and flourish.

1. Token Policy Standard
2. Identity and Eligibility Checks
3. Lifecycle Management and Corporate Activities

Practical Building Blocks:

• Foundation: This is the backbone of any building. Having a strong foundation is key to keeping everything stable and secure.
• Walls: They offer protection and a sense of security. On top of that, they help shape the different areas in your building.
• Roof: It’s what keeps everything safe and sound up there, shielding us from rain, sun, and snow.
• Windows and Doors: They bring in natural light and offer easy access, giving your space a welcoming and airy vibe.
• Utilities: Make sure you keep plumbing and electrical systems in mind--they’re super important for both comfort and functionality.
• Finishes: Flooring, paint, and fixtures really add character and style to your space.
• Landscaping: The perfect finishing touch! Thoughtfully designed outdoor areas can really boost both the look and functionality of your space.
• Permissioned token standards you should keep an eye on
  • ERC‑3643 (T‑REX): This one's got your back with ERC‑20 compatibility and a bunch of cool features. We're talking about an identity registry, compliance modules, agent roles, and even options to pause, freeze, or force transfers. And to top it off, it has compliance pre-checks and recovery flows, making sure everything runs smoothly with those pesky regulatory constraints. If you’re using ONCHAINID, this is definitely worth checking out. Dive into the details here.
  • ERC‑1404: Picture this as a simple "restricted transfer" interface. It works great alongside lockups and whitelists, plus it offers pre-flight “reason codes” that wallets and exchanges can easily get. If you want to know more about it, take a look here.
  • ERC‑4626: This standard focuses on vault shares for yield-bearing tokens, making it super useful when you're handling money market or treasury exposure. Want to dig deeper? Check it out here.
• Identity and eligibility
  • Link wallet addresses to verified identities (think ONCHAINID) and add info such as jurisdiction, investor type, and sanctions status as claims. Don't forget to implement compliance modules to ensure that only eligible identities can either receive or hold the token--this should apply even when they're transferred across different chains. (erc3643.org)
• Data standards for listings, risk, and reconciliation
  • The ISO 24165 Digital Token Identifier (DTI) is super important for token implementations, and it’s awesome to see it linked to ISIN where it makes sense. With the updates coming in 2025 for ISO 24165‑1/‑2, we can expect a solid formalization of registration and metadata, which should really pave the way for broader global adoption. Using the DTI is crucial--it helps distinguish an asset from its specific representation on the blockchain, which is essential for things like portfolios, fund accounting, and disclosures. You can check it out here: (iso.org)
• On-chain corporate actions and fund data
  • DTCC’s Smart NAV pilot has really demonstrated how standardized NAV dissemination can operate on-chain across various networks. It's super easy to link up your transfer agent or fund administrator to send price and rate data that smart contracts can work with for primary issuance and redemptions. Take a look at it here: (dtcc.com)

Governance Anti‑Patterns to Avoid:

When it comes to governance, there are definitely some common missteps that can throw a wrench in the works. Here’s a rundown of these anti-patterns so you can dodge them:

1. Top-Down Approach
   In this method, a select few at the top make all the decisions, and the rest of the team is left out of the loop. It might look efficient on the surface, but it usually causes team members to feel disconnected and even resentful.
2. Lack of Clarity
   When roles and responsibilities aren’t clearly laid out, confusion takes over. This can lead to people working on the same tasks, leaving others unattended, and a whole lot of frustration for everyone involved.
3. Over-Complicated Processes
   Sure, having a super detailed approval process might seem like a good idea to keep things in check, but it can really kill creativity and drag down progress. So, let’s keep it simple!
4. Ignoring Feedback
   Dismissing feedback from your team can create an atmosphere where folks feel unappreciated. Make it a point to really listen to what they have to say--it's beneficial for everyone involved!
5. Neglecting Change Management
   Change can be tough, and if we overlook how it affects people, things can get chaotic pretty quickly. It's crucial to take a proactive approach to manage transitions and ensure everything runs smoothly.
6. Inflexibility
   Sticking too hard to a plan, even when things take a turn, can really backfire. So, remember to stay flexible!
7. Failing to Measure Success
   If you don’t take a moment to see how things are going, you’re missing out on opportunities to get better. Make sure to establish some metrics to monitor your progress, and don’t forget to celebrate those victories along the way!

By staying alert to these anti-patterns, you can foster a more positive governance environment that really boosts collaboration and sparks innovation.

• If you're thinking about going with a “permit-all” ERC‑20 that uses off-chain KYC lists, just a little warning: you might run into some issues with MiCA custody rules concerning client registers and rights management. Plus, keeping an eye on sanctioned flowbacks could get pretty complicated. A smarter option? Consider doing pre‑transfer checks on-chain. (ashurst.com)
• Be careful with those fuzzy bridge wrappers! Without DTI/ISIN mapping and chain‑agnostic role controls, your reconciliations could be a headache during audits. Instead, it’s better to use DTI along with a registry that links bridged representations to the same underlying asset. (iso.org)

2) Custody: design for segregation, resilience, and capital efficiency

These days, institutional custody is all about blending MPC, HSM, and tailored procedures, along with off-exchange settlement to keep venue credit risk under wraps.

• Key management stack
  • We’ve got FIPS 140‑3 validated modules (HSMs) in place to create some pretty solid cryptographic barriers. With the magic of Multi-Party Computation (MPC), we can tackle everything from threshold signing to key-share rotations and even air-gapped co-signing. Our firewalls keep things secure by ensuring quorum, time-locks, and policy engines that are connected to chain analytics. For more details, feel free to check this out: (csrc.nist.gov)
  • We’re also on top of the latest MPC tech, like MPC‑CMP, which allows for single‑round signing, regular key-share refreshes, and fully air-gapped options. It's super convenient whether you’re dealing with warm or cold tiers, and the best part is everything keeps running seamlessly. Plus, there are open-sourced implementations out there that make audits a piece of cake. Want to dive deeper? Check this out: (fireblocks.com)
• Client Asset Segregation and Sub-Custody
  • According to the guidance from NYDFS, it’s crucial to keep customer assets completely separate from the firm’s own assets--no mixing allowed! You also need to make sure you’re giving clear disclosures and have well-defined sub-custody arrangements in place. It’s a smart move to adopt this mindset on a global scale; under MiCA, you’ll want to keep a register for client positions and ensure clients maintain their rights automatically (like those cool forks and airdrops). Plus, be cautious about commingling, even within your own group, and only partner with authorized CASP sub-custodians. (dfs.ny.gov)
• Off‑exchange settlement (OES) patterns
  • Keeping your assets in a qualified or independent custody while trading on centralized platforms is definitely a smart play. This approach lets you use credit mirrors and on‑chain collateral vaults, which helps to reduce counterparty risk and minimize that annoying capital drag throughout the trading day. More and more vendors and networks are getting behind OES, and we’re starting to see real-world applications popping up in places like Deribit, along with partnerships with major global exchanges. Want to learn more? Check it out here.
  • We’re also witnessing the rise of multi‑custodian OES networks, like the BitGo-Copper pipeline. This setup helps dodge the risks that come with depending on a single custodian, all while keeping those settlements happening in real time. For the nitty-gritty details, hit this link: businesswire.com.
• Banking Rails Alignment
  • With the rescinding of SAB 121 and the green light from OCC IL 1183/1184, U.S. banks are back in the game as primary or sub-custodians for crypto! As long as they follow standard risk management practices, they can dive right in. This really opens up some cool possibilities for bankruptcy-remote, bank-trust models. (sec.gov)
• DORA considerations
  • When you're thinking about your custody stack and chain infrastructure, consider it a key part of your ICT. It's important to get some solid incident reporting processes in place, run resilience tests (and remember to test that MPC signer failover and enclave recovery), and don’t skip over the need for contractual agreements that ensure EU oversight for those “critical” third-party services like cloud providers. (alston.com)

3) Controls: compliance and operations engineered into the protocol

• Travel Rule and Fund Transfers
  • If you're making transfers within the EU, it’s time to get ready for the Reg. 2023/1113 “Travel Rule.” You'll want to implement this messaging at the service edges (think VASP↔VASP and VASP↔PSP). This is all part of the EBA guidelines coming into play on December 30, 2024. Be sure to include checks for both originator and beneficiary data, and don’t forget those “insufficient information” playbooks! You can dive deeper into the details here: (eba.europa.eu)
• MiCA custody obligations in code
  • You’ve got to keep separate registers for each client, making it simple for them to exercise their rights. Any changes to those rights? Record them quickly and whip up quarterly statements automatically. Don't just hide behind “terms of service” when it comes to corporate actions--make sure these requirements are woven into your admin agents and off-chain services that link up with your token contracts. (ashurst.com)
• Data lineage and identifiers
  • Connect DTI/ISIN and fund details (such as Smart NAV) on-chain, and spread that info across risk, finance, and disclosure systems--while keeping an eye on the 2026 Basel disclosures. Check out more details here!
• Operational Analytics and Logging
  • Stay aligned with DORA: ensure you have clear visibility throughout the whole token lifecycle, including minting, burning, and force transfer events, plus decisions from the policy engine and signer telemetry. Also, set up a reporting process for “major ICT incidents” to fulfill the guidelines laid out by local competent authorities. (alston.com)

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Live precedents you can learn from (and build on)

• Tokenized Fund Data Pipelines: DTCC Smart NAV
  DTCC just launched an exciting pilot program to enhance how NAV data gets shared on-chain across various networks. They've teamed up with heavyweights like Franklin Templeton, JPMorgan, State Street, BNY Mellon, and a few others. This initiative is geared towards smoothing out those pesky operational bumps when it comes to tokenized funds. Dive in for all the juicy details! (dtcc.com)
• Money-Market Funds as Collateral (Bank-Grade)
  JPMorgan's Onyx Tokenized Collateral Network (TCN) has opened the door for tokenized money-market fund (MMF) shares to be used as collateral between big players like BlackRock and Barclays. This is pretty exciting because it highlights how fast these operational flows can occur. And if that wasn’t enough, Fidelity International has also jumped in and tokenized their MMF shares to use on Onyx. For more details, check it out here.
• BlackRock BUIDL’s Expansion and Controls Model
  Back in March 2024, BlackRock launched its USD Institutional Digital Liquidity Fund, known as BUIDL, which is tokenized by Securitize on Ethereum. Since then, they’ve expanded their share classes across different chains. To help prevent spoofing, BlackRock shares the official token addresses. Plus, BUIDL has been accepted as collateral on multiple platforms and facilitates USDC on-ramping through partnerships with Zero Hash. You might find some useful ideas here for creating permissioning, allowlists, and collateral workflows. (securitize.io)
• Franklin Templeton BENJI (FOBXX)
  Alright, so this is a U.S. ’40‑Act on-chain money market fund that’s got some pretty neat features. You can do peer-to-peer transfers and even convert to USDC through a secure process. And the best part? You can check out daily stats on liquidity and the portfolio. This really shows how regulated funds can tap into token features while keeping that transfer-agent control in the mix. If you want to dive deeper, take a look here: (franklintempleton.com)
• Market size: tokenized Treasuries
  By mid-2025, reliable trackers and media sources are predicting that tokenized Treasuries and similar products, like money market funds, will soar to several billion dollars. This growth highlights their rising popularity as cash collateral and yield-generating alternatives to just sticking with stablecoins. What’s driving this surge? Well, it’s all about the need for intraday collateral, continuous liquidity, and the flexible settlement options. (ft.com)

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Reference architectures we deploy at 7Block Labs

A. Tokenized Treasuries for corporates (US + EU distribution)

Objective

We're on a mission to develop a permissioned, yield-bearing token that will represent shares in our fund. This token is designed for instant settlements and collateral use, all while making sure we follow the guidelines laid out by MiCA (EU) and comply with U.S. custody and banking regulations.

• Token Layer
  • We’re rolling with the ERC‑3643 share token, which comes packed with some awesome compliance features. It has jurisdiction allowlists (think EEA and U.S. Reg D/QIB), investor caps, and holding periods. On top of that, we’ve got a corporate actions agent in place to manage distributions and redemptions. The DTI is ready to go and linked to ISIN in our static data service. Check it out here: (ercs.ethereum.org)
• Identity and Onboarding
  • We handle ONCHAINID accounts through our KYC provider, making the process smooth. We've also got MiCA roles integrated, so you’ll easily know who’s who--whether they're a client or a CASP. Plus, we’ve set up Travel Rule connectors right at the edge. For more details, check out (erc3643.org).
• Fund Admin + Transfer Agent
  • We’ve got a Smart NAV publisher contract that grabs the daily NAV from the transfer agent, and it works in a way that's pretty similar to how DTCC operates. The main issuance and redemption windows are linked to the NAV timestamp, which really keeps things running smoothly. You can dive into the details here: (dtcc.com).
• Custody and Keys
  • When it comes to client assets, we've got a solid setup with a bank sub-custodian (thanks to that post-SAB 122 flexibility). Our system includes an MPC-backed policy engine and HSM co-signers to keep everything secure. We're all about following the NYDFS/MiCA guidelines for segregation, and we've got multi-region disaster recovery fully in place. Want to dive deeper? Check this out: (sec.gov).
• Trading and Collateral
  • With our OES integration, we’re now able to access derivatives venues for using collateral. We’ve implemented credit mirrors that adjust in real-time on-chain, and our intraday liquidity lines are controlled by set limits within the policy engine. Want to learn more? Check it out here: (fireblocks.com).
• Resilience and Compliance
  • We're big on resilience! Our DORA incident feed goes directly to the relevant authority. Plus, we automatically generate client statements every quarter right from our on-chain positions registry. And when it comes to cross-border flows, we’re totally on top of the FATF Travel Rule message broker. If you want to dig deeper, check this out: (alston.com).

KPIs to Keep an Eye On

• Time-to-Settle: Let's take a look at T+0 compared to T+1
• % Collateral Reuse
• Issuer Spread vs. ETF Shares
• MiCA Statement SLA
• Incident MTTR
• Redemption Fail Rate

B. Multi‑asset tokenization program for an asset manager

Our Goal:

We're excited to introduce tokenized funds, featuring options like Money Market Funds (MMF), fixed income, and alternative credit. What makes this really interesting is that they’ll operate seamlessly across various blockchains, plus we’re adding bank-grade sub-custody for that added peace of mind.

• Standards and Registries
  • Every product is assigned a one-of-a-kind DTI, and we connect cross-chain representations using a registry. On top of that, we have ERC‑4626 wrappers for vault-like products and ERC‑3643 for pools that are designed for approved investors. You can dive deeper into this here.
• Collateral and Repo
  • We’re excited to dive into integrating with bank networks, adopting TCN-style patterns for using tokenized shares as collateral. With pre-approved counterparties through identity claims, you'll be able to pledge and unpledge almost on the fly. Curious to learn more? Check out this article.
• Controls
  • We’ve got MiCA Article 75 covered for registering services, managing forks and airdrops, and streamlining corporate actions. Plus, there’s some handy Travel Rule middleware to help things flow easily across EU corridors. Don't forget the Basel disclosure feeds coming straight from the subledger, including those DTI roll-ups. If you’re curious, check out this insight for more details!

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Implementation playbook: 30/60/90 days

• 30 days
  • Regulatory gap mapping: Dive into MiCA Title VII CASP responsibilities for the EU, see how DORA fits into the picture, check out what U.S. SAB 122 means for you, and find out if NYDFS is relevant. Make a decision on who your main regulator(s) will be and think about whether you want to be a CASP yourself or team up with one. (ashurst.com)
  • Standards selection: Opt for ERC‑3643 when it comes to permissioned shares and go with DTI for your token IDs. Also, let's nail down your cross‑chain strategy--are you leaning towards a single canonical chain with some flexible reads via oracles, or maybe something more adventurous like multi‑chain share classes, such as BUIDL? (ercs.ethereum.org)
  • Custody RfP: Put together a shortlist of MPC+HSM custodians. Make sure to mention the need for FIPS 140‑3 modules, multi‑sig/M‑of‑N setups, and geo‑redundancy in your requirements. Don't forget to ask for MiCA-compliant client registers and sub‑custody controls as well. (csrc.nist.gov)
• 60 days
  • Let’s get those compliance modules rolling! We need to encode eligibility criteria, geography specifics, and lockup details; wire up ONCHAINID; and integrate that Travel Rule gateway for EU transactions. If you want to dive deeper into this, check it out at (erc3643.org).
  • On the data front, we’re aiming to roll out a Smart NAV-type feed from our transfer agent. This needs to be published to an on-chain oracle, where we’ll assign those DTIs and ensure everything is in sync with our ISIN master. Want more info? Hit up (dtcc.com).
  • For the OES pilot, let’s kick things off by setting up a collateral vault with one venue. We’ll run some tests on margin cycles and figure out how to handle emergency withdrawals. Get the latest on this at (fireblocks.com).
  • As for DORA controls, we need to zero in on incident classification, create a reporting API for the relevant authority, assess vendor criticality, and draft a plan for resilience testing. You can find more details at (alston.com).
• 90 days
  • Limited-access launch: Let’s get 10-50 investors on the whitelist; keep an eye on T+0 settlement and redemption SLAs; plus, we should run some failover drills--like what happens if we lose a signer or face a cloud region outage.
  • Audit readiness: We need to ensure our SOC 2 covers custody operations; automatically whip up those MiCA Article 75 quarterly statements; and do some Travel Rule QA with our counterparties. (ashurst.com)

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Emerging best practices we recommend in 2025

• Use dual control planes: Make sure to do your policy checks on-chain with pre-transfer hooks, and then mirror them off-chain with a risk engine. This way, you can avoid any weird flows when L1 gets busy.
• Go for DTIs at issuance: It’s way easier to tackle this upfront rather than trying to fix it later. Plus, DTIs are now a vital part of ISO standards that various data vendors and disclosure stacks follow. Check it out here: (iso.org).
• Treat identity like a ledger: Keep those claims immutable, complete with expiry dates, revocation options, and audit trails. Don’t just let KYC results gather dust in separate databases. For more info, take a look at (erc3643.org).
• Design for sub-custody transparency: Both MiCA and NYDFS want to know who’s holding client assets at every stage. So, make it a point to include sub-custodian addresses and their capabilities directly in the metadata. Get the details here: (esma.europa.eu).
• Build in operational resilience: Don't forget, DORA will be checking up on your cloud and MPC vendors. It’s smart to run red-team key-loss simulations and keep tabs on your recovery ceremonies. For guidance, check this out: (alston.com).

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Brief, in‑depth example: governance and controls for a cross‑border tokenized MMF

Scenario: A Luxembourg Umbrella Fund with a Delaware Feeder

Alright, here's the scoop: we've got a Luxembourg umbrella fund that's trying to get everything in order, especially when it comes to a Delaware feeder. What they're really going for are permissioned, cross-chain share classes.

• Token policy: We're going with ERC‑3643 for our token setup, which means we’ve got compliance sorted out for each compartment. So, no EU retail, but U.S. QIBs are all set to roll. Just a heads-up, there are some transfer limits depending on the country, and the issuer will take on an "agent" role to deal with any emergency freezes or recalls, as per the prospectus. You can read more about it here: (ercs.ethereum.org)
• Identity: For MiCA-compliant CASP onboarding and local KYC, ONCHAINID checks all the necessary boxes.
• Data: We're sending out daily NAV updates using a DTCC-style publisher. Each share class is assigned a DTI, and we have specific windows for issuing and redeeming tied to the NAV. If you want to dive deeper, check it out here: (dtcc.com)
• Custody: An EU CASP is in charge of custody and administration as per Article 75. They’re also handling client registers and quarterly statements. For our U.S. operations, we have a bank sub-custodian set up post-SAB 122, but keep in mind that sub-custody is only available to authorized CASPs. Get the full scoop here: (ashurst.com)
• Controls: We’re enforcing the EU Travel Rule at the service edge. And about fork handling, we keep it client-friendly unless someone gives us clear opt-out consent. This aligns with the ESMA Q&A guidelines. For more details, take a look here: (esma.europa.eu)
• Trading: We’ve integrated OES to use shares as collateral for derivatives. There are some policy limits on reuse and the haircut logic to keep everything balanced. For more insights, check this out: (fireblocks.com)

Key Outcome Metrics to Aim For

• Issuance Settlement: Aim for 60 seconds or less.
• Collateral Pledge/Unpledge: Let’s keep this under 2 minutes.
• Service Uptime: We’re shooting for 99.9% uptime.
• Travel Rule Exceptions: No unresolved exceptions should hang around for more than 24 hours.
• DORA Tabletop: Get this wrapped up within 30 days of going live.

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How 7Block Labs engages

• Readiness Assessment: We’re taking a good hard look at how MiCA, DORA, and SAB 122 are going to shake things up. We're figuring out which governance standards to adopt and exploring custody options along the way.
• Build and Integrate: We're diving into the nitty-gritty of ERC‑3643 and ERC-1404 tokens, setting up ONCHAINID gating, making sure Smart NAV drinks up data just right, mapping DTI to ISIN, and throwing in some Travel Rule middleware for good measure. And hey, don’t miss the OES pilots! You can find out more about that here.
• Operationalization: We're hard at work on DORA incident pipelines, whipping up Article 75 statements, running MPC/HSM ceremonies, and piecing together SOC 2 evidence packs. If you want to dig deeper, check out this link.

Get in touch with us, and we’ll help you review your current plans using this governance-custody-controls blueprint. Together, we’ll whip up a tailored 90-day plan that prioritizes your regulatory needs and asset mix.

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Sources and further reading

• Want to stay in the loop on MiCA timelines, how the Travel Rule plays into things, and ESMA’s insights on custody and shared order books? You can find everything you need here.
• Got questions about DORA’s effective date and the ins and outs of provider oversight? You can dive into all the juicy details here.
• The SEC just pulled the plug on SAB 122, and there’s some key info from OCC IL 1183/1184 regarding crypto custody and execution. Get the lowdown here.
• Don’t miss out on all the buzz about DTCC Smart NAV and updates related to the ERC-3643/1404/4626 standards. Plus, check out the ISO 24165 DTI updates coming your way in 2025. All the scoop is right here.
• If you're intrigued by off-exchange settlement patterns and how they integrate, you can read up on it here.
• And finally, don’t forget to check out the NYDFS guidance on custody segregation and the operational expectations highlighted in MiCA Article 75. Find all the info here.

7Block Labs is ready to bring these principles to life with production systems that you can easily audit, scale, and stand behind.