For Enterprise banking leaders evaluating “Wallet-as-a-Service,” the fastest path to on-chain revenue without regulatory whiplash is a hybrid build/buy that meets SOC 2, FFIEC third‑party risk, and MiCA/DORA obligations while keeping key management under your control. Below is the pragmatic playbook we use at 7Block Labs to de‑risk procurement, cut time‑to‑market, and prove ROI in 90 days.

The “Wallet‑as‑a‑Service” Landscape: Build vs. Buy for Banks

Target audience: Enterprise (Banks). Keywords included where relevant: SOC 2 Type II, FFIEC Third‑Party Risk, DORA/MiCA, FIPS 140‑3, OCC/OFR oversight, RTO/RPO, Segregation of Duties, KYT/Travel Rule, ERP/GL reconciliation.

— Pain — Agitation — Solution — Proof.

Your wallet project is stuck between compliance, procurement, and engineering “unknowns”

You need on‑chain accounts, transfers, and policy controls, but Security wants FIPS‑validated HSMs/TEEs, Audit wants SOC 2 Type II and ISO controls, and Risk wants FFIEC‑aligned third‑party oversight end‑to‑end. The interagency third‑party risk management guidance makes the bank responsible across planning, due diligence, contracting, ongoing monitoring, and termination, even if a WaaS vendor fails. (federalreserve.gov)
Accounting changed: the SEC rescinded SAB 121 via SAB 122 effective January 30, 2025, shifting crypto custody accounting away from on‑balance‑sheet “safeguarding liabilities” to ASC 450 loss‑contingency analysis—altering capital and disclosure assumptions in your business case. (sec.gov)
EU operations raise new obligations: MiCA Titles III/IV for stablecoins applied from June 30, 2024 and full MiCA/DORA application followed by December 30, 2024/January 17, 2025, with EBA “travel rule” guidelines effective December 30, 2024—so compliance architecture must be in‑by‑design, not bolted on. (finance.ec.europa.eu)
Engineering trade‑offs are real: do you trust vendor‑managed MPC, require bank‑controlled MPC nodes, or insist on HSMs (FIPS 140‑3) in your environment? Each changes threat models, RTO/RPO, and vendor lock‑in risk. AWS KMS and CloudHSM now provide FIPS 140‑3 Level 3 options, but integration details matter. (csrc.nist.gov)
Meanwhile, L2 fee dynamics changed post‑Dencun (EIP‑4844 “blob” space), which primarily reduces L2 fees—affecting cost modeling for ERC‑4337/AA flows and sponsored gas policies. (blog.ethereum.org)

Result: missed launch windows, rework in InfoSec reviews, and budget churn as pricing, compliance, and architecture targets keep shifting.

The hidden risks that blow up timelines and budgets

Procurement risk: Without an FFIEC‑aligned TPRM pack, your vendor can be “technically fine” yet still fail legal/operational due diligence—stalling at contract. Expect scrutiny on lifecycle controls (planning → termination), sub‑processor maps, and right‑to‑audit language. (federalreserve.gov)
Accounting risk: If your model still assumes SAB 121 liabilities, your capital and KPI projections are wrong post‑Jan 2025 (SAB 122)—and your CFO will block the Go/No‑Go until it’s restated. (sec.gov)
Regulatory fragmentation: EU travel rule routing, MiCA stablecoin constraints, and U.S. BSA/AML travel rule thresholds (with cross‑border thresholds historically proposed down to $250) complicate VASP‑to‑VASP data exchange and self‑hosted wallet flows if not engineered from day one. (eba.europa.eu)
Security regressions: MPC in TEEs is powerful, but auditors will still ask about cryptographic libraries, enclave attestation, geo‑distribution of key shares, and the vendor’s SOC 2 Type II posture and ISO certifications. Fireblocks’ trust center and Coinbase/Circle disclosures help, but you need controls mapping into your RCSA. (trust.fireblocks.com)
Cost surprises: WaaS pricing is no longer opaque. Coinbase Embedded Wallets bill per operation ($0.005/write op; first 5,000 ops free), while Circle charges per Monthly Active Wallet with tiered MAW pricing and a USDC rebate; sponsored gas (ERC‑4337 paymasters / Gas Station) adds a platform fee plus the chain’s gas, so your COGS depends on user behavior and chain selection. (docs.cdp.coinbase.com)
EU resilience: DORA demands demonstrable operational resilience and third‑party ICT oversight. If your WaaS isn’t mapped to incident/breach reporting (e.g., U.S. FTC Safeguards Rule notification in 30 days for certain non‑bank FIs), you risk post‑incident regulatory findings. (finance.ec.europa.eu)

This is where 7Block Labs steps in with a build‑vs‑buy framework designed for banks—not for startups.

7Block Labs’ methodology for banks (90‑day pilot to ROI)

We combine deep protocol engineering (Solidity, ZK) with bank‑grade delivery (risk, controls, procurement). Our approach is deliberately “Technical but Pragmatic.”

Business‑Case and Controls Baseline (Week 0‑2)

Recast the P&L with SAB 122 accounting, L2 fee models post‑Dencun, and WaaS unit economics.
Map obligations: FFIEC TPRM lifecycle; SOC 2 Type II/ISO 27001/27017/27018; DORA/MiCA in EU; Travel Rule (U.S./EU) routing; FTC Safeguards (for non‑bank affiliates). Deliverables include control matrices, evidence lists, and RACI for vendor governance. (fdic.gov)

Architecture Options—Bank‑Controlled Keys vs. Vendor‑Managed (Week 2‑4)

MPC topologies:
- Vendor‑hosted MPC shards: fast time‑to‑market (e.g., Circle’s hosted 2‑of‑2 for user wallets; “Server Wallets” for programmatic flows). (developers.circle.com)
- Shared custody MPC: bank hosts one MPC node (Circle keyguard flow); reduces vendor lock‑in and aligns with stricter jurisdictions. (developers.circle.com)
- Bank‑hosted dual MPC or HSM hybrid: keep keys in your perimeter with FIPS 140‑3 HSMs, integrate WaaS only for orchestration/UX abstractions. (csrc.nist.gov)
Account Abstraction and UX:
- ERC‑4337 smart accounts with passkeys/social login; gas sponsorship via paymasters on EVM; Solana/Aptos handled via fee payer mechanisms. (eips.ethereum.org)
Chains:
- EVM L2s (benefit from EIP‑4844 blob space fee reductions), plus Solana where throughput/latency matters; evaluated against compliance and liquidity. (blog.ethereum.org)

Vendor Shortlist and Scoring (Week 4‑6)

Coinbase Developer Platform (Embedded + Server Wallets): TEEs for keys, “self‑custody by default,” built‑in KYT controls, op‑based pricing ($0.005/operation, first 5k free). Strong for rapid embedded UX and U.S. retail reach. (coinbase.com)
Circle Programmable Wallets: granular MPC hosting choices (0/1/2 nodes by Circle vs. you), MAW pricing with USDC rebates, compliance engine (travel rule early access, transaction screening beta), ERC‑4337 Gas Station with 5% fee on sponsored gas. Strong for stablecoin‑native flows and multi‑chain. (developers.circle.com)
Fireblocks: MPC‑CMP with audited, open‑sourced library, SOC 2 Type II/ISO certifications, policy engine, and Notabene travel rule integration. Strong for institutional treasury/custody and internal controls depth. (fireblocks.com)
BitGo: TSS‑based MPC with 2‑of‑3 model, multi‑sig/HSM options, and—as of December 2025—OCC conditional conversion approval to a national trust bank, relevant for qualified custody alignment. Strong for fiduciary custody and segregation. (developers.bitgo.com)

Pilot Build (Week 6‑12) with “compliance‑first” integrations

Scope: 10k wallets, 3 transaction types, full policy engine, sanctions/KYT + travel rule, and ERP/GL reconciliation.
Tech sprints:
- Wallet orchestration SDKs + bank SSO/IDP.
- Policy contracts (Solidity) for daily limits, 4‑eyes controls, velocity checks, smart‑account recovery.
- ZK attestations for selective‑disclosure proofs (e.g., proof of KYC’ed status to counterparties) without exposing PII; optional in Phase 2.
- Observability: audit logs, chain analytics events, and immutable proofs for internal audit.
Controls sprints:
- TPRM evidence packet, SIG Lite/Full alignment, penetration test scheduling, disaster‑recovery runbook tied to RTO/RPO.
We implement this with our web3 development services, custom blockchain development services, security audit services, and enterprise blockchain integration.

Scale and Transition (Post‑Pilot)

Vendor diversification (e.g., dual providers for different geos).
Performance tuning: bundler selection (ERC‑4337), signature aggregation where applicable, and gas policy optimization.
Ongoing change management mapped to FFIEC/DORA.

What’s new in 2025‑2026 that changes your Build vs. Buy calculus

Accounting relief: SAB 121 is gone—SAB 122 rescinds Topic 5.FF and points to ASC 450. That reduces capital drag for custody lines and makes revenue projections less punitive. Update your CFO deck. (sec.gov)
OCC trust‑bank lane is open again: by December 2025, the OCC conditionally approved national trust charters for multiple digital‑asset players (including BitGo conversions). If your strategy includes “qualified custody” or nationwide fiduciary service without state‑by‑state patchwork, align roadmaps accordingly. (occ.gov)
ERC‑4337 and Dencun matured: smart‑account UX and L2 economics now justify embedded wallet flows at retail scale; but budget for sponsored gas and choose L2s with stable blob markets. (eips.ethereum.org)
EU: MiCA/DORA are live; EBA travel rule guidelines applied from December 30, 2024. Add automated VASP discovery and PII exchange (IVMS101), or leverage a WaaS “compliance engine” early‑access feature set. (eba.europa.eu)
HSMs and TEEs: FIPS 140‑3 Level 3 options for AWS KMS/CloudHSM simplify InfoSec sign‑off for bank‑controlled keys, including enclave‑anchored MPC nodes or policy oracles. (csrc.nist.gov)

Practical examples

Retail stablecoin payments under strict controls (U.S. + EU footprint)

Target: launch a consumer wallet with USDC rails, ERC‑4337 UX (email/passkey onboarding), and bank‑hosted compliance logic.
Architecture:
- Circle Programmable Wallets for modular MPC (start with Circle‑hosted nodes to ship fast; migrate one node on‑prem in Phase 2). Circle’s Gas Station sponsors EVM smart‑account gas; fee = cost + 5%. Circle’s Compliance Engine adds transaction screening and travel rule workflows. (circle.com)
- Paymaster policies: daily gas caps by customer segment; bundler SLAs with automated fallback.
- EU stance: MiCA‑compliant stablecoin usage; Travel Rule enforced via pre‑trade screening + secure PII exchange.
Economics:
- Wallet unit costs (MAW‑based tiers with USDC rebate) vs. expected monthly active rate; sponsored gas budget pegged to L2 fee scenarios post‑EIP‑4844. (circle.com)
7Block deliverables:
- Smart‑account templates with policy hooks, passkey recovery flows, monitoring dashboards, and a TPRM evidence binder covering SOC 2 Type II, ISO mappings, and breach‑notification runbooks (FTC Safeguards for non‑bank affiliates). (ftc.gov)

Institutional custody with policy depth and travel rule automation

Target: corporate treasury custody and settlement with multi‑user approvals, segregation, and cross‑jurisdiction compliance.
Architecture:
- Fireblocks for MPC‑CMP, policy engine (allowlists, velocity limits), auditor‑friendly controls (SOC 2 Type II, ISO), and Notabene travel rule integration. (trust.fireblocks.com)
- Optionally layer BitGo for fiduciary custody and 2‑of‑3 TSS wallets, aligned with its OCC national trust conversion trajectory. (developers.bitgo.com)
- Key strategy: shard geo‑distribution across TEEs/HSMs; bank‑controlled recovery; independent attestation of enclaves.
7Block deliverables:
- Segregation of duties in signing flows, ledger postings to ERP/GL, sanctions/KYT routing, and immutable activity proofs for internal audit.
- Formalized RTO/RPO and chaos‑testing of withdrawal policies.

Embedded wallets inside an existing mobile app

Target: fast, branded onboarding with minimal crypto UX friction.
Architecture:
- Coinbase Developer Platform (Embedded Wallets) for email/SMS/OAuth onboarding, TEE‑backed key handling, KYT screening, and simple op‑based pricing ($0.005 per write; 5k free per month). Ideal for a “phase‑one” launch with U.S. retail reach. (coinbase.com)
- AA upgrade path: add ERC‑4337 features (sponsored gas, batch ops) as adoption grows. (eips.ethereum.org)

Emerging best practices (what we implement by default)

Key custody choices as a spectrum—not a binary:
- Start vendor‑hosted MPC for speed; evolve to shared‑custody or bank‑hosted MPC/HSM for control and exit options.
“Compliance‑in‑code”:
- Encode Travel Rule pre‑checks and sanctions gates in your transaction queue; leverage WaaS compliance engines where available. (circle.com)
ERC‑4337 “safety rails”:
- Rate‑limit sponsored gas by customer tier; enforce approved bundlers; adopt signature aggregation when stable to reduce fees. (ercs.ethereum.org)
DORA/FFIEC observability:
- Proactive telemetry, immutable logs, synthetic transactions, and documented incident thresholds that align to breach‑notification windows. (finance.ec.europa.eu)
FIPS‑anchored cryptography:
- Prefer FIPS 140‑3 validated modules (CloudHSM/KMS) for bank‑hosted components; document enclave attestation for any TEE‑based MPC nodes. (csrc.nist.gov)
“Right‑to‑exit” plan:
- From day 1, maintain key‑material portability, AA signer portability, and ledger export formats; simulate vendor exit quarterly.

Build vs. Buy: a banker’s decision tree (TL;DR)

Buy (WaaS‑first) if:

You need to prove demand in ≤90 days, with consumer‑grade UX (passkeys/email), and can accept vendor‑managed MPC initially.
You can align SOC 2 Type II + ISO evidence to procurement and accept per‑op or MAW pricing. (docs.cdp.coinbase.com)

Build (bank‑first) or Hybrid if:

You must control MPC nodes/HSMs for policy, recovery, or jurisdictional requirements (e.g., bank‑hosted key shares).
You require fiduciary/qualified custody alignment (OCC trust bank orientation) or deep ERP/GL controls beyond typical WaaS. (occ.gov)

Either way, use L2s post‑Dencun to keep unit economics attractive; model sponsored gas with real user behavior, not lab assumptions. (blog.ethereum.org)

What 7Block Labs delivers that de‑risks procurement and accelerates ROI

A single team spanning protocol engineering and bank governance:
- Solidity smart‑account engineering, ZK attestations, and enclave/HSM integrations.
- FFIEC/DORA‑aligned TPRM packs, SOC 2 Type II mappings, breach‑notification runbooks.
Vendor‑agnostic scoring and integration:
- We shortlist, negotiate, and integrate WaaS providers—then we ensure “right‑to‑exit” by design.
90‑day pilot with measurable KPIs:
- Target “money metrics” we align up front:
  - Time‑to‑first on‑chain transaction in production (≤6 weeks).
  - KYC’d wallet activation rate (conversion uplift from passkeys/social login).
  - Unit COGS per active wallet/operation vs. baseline (L2 + sponsorship).
  - Incident MTTR and RTO/RPO adherence in failover drills.
From pilot → scale:
- We transition from “one chain, one WaaS” to multi‑provider, multi‑region, with enterprise support, SRE playbooks, and quarterly exit simulations.

Explore our relevant offerings:

End‑to‑end dApp development solutions and smart contract development
Enterprise DeFi development services with policy‑guarded flows
Cross‑chain solutions and bridge development where custody and movement intersect
For tokenized assets and programs: asset tokenization and asset management platform development
If capital formation is in scope: fundraising advisory

Proof points you can take to GTM

Compliance alignment out of the box:
- Interagency TPRM mapped to contract, SLAs, and monitoring. (federalreserve.gov)
- SOC 2 Type II reports and ISO mappings (e.g., Fireblocks Trust Center) in the vendor pack. (trust.fireblocks.com)
- EU MiCA/DORA playbooks with travel rule workflows configured in the pilot (where available via WaaS compliance features). (finance.ec.europa.eu)
Cost transparency:
- Coinbase: per‑write op pricing at $0.005; first 5k free—simple CFO modeling. Circle: MAW tiers with USDC rebate; Gas Station fee + the chain’s gas. We wire these into COGS dashboards. (docs.cdp.coinbase.com)
Security depth:
- MPC/TEE transparency: Coinbase whitepaper and Fireblocks MPC‑CMP open‑sourced; FIPS 140‑3 HSM options for bank‑controlled keys. (coinbase.com)
Market readiness:
- Post‑Dencun fee dynamics reduce L2 costs for AA bundles; our pilots demonstrate fee curves with real usage. (blog.ethereum.org)
Regulatory runway:
- OCC national trust charter momentum (Dec 2025) signals clearer federal supervisory lanes for crypto custody—useful in long‑term planning if you want qualified custody services in‑house or via partner. (occ.gov)

The bottom line

For banks, “Wallet‑as‑a‑Service” is no longer a binary choice. The winning pattern in 2026 is a staged hybrid: start with WaaS to validate demand and UX, keep keys and policies progressively under bank control, and bake compliance into the transaction path—not the slide deck.
7Block Labs builds that path with a 90‑day pilot that your CISO, CFO, and Head of Retail can all sign off on: measurable ROI, SOC 2‑ready evidence, and an exit plan before day one.

Ready to move from slides to transactions?

Book a 90‑Day Pilot Strategy Call

References and source notes

Interagency TPRM guidance (June 6, 2023): Federal Reserve, FDIC, OCC. (federalreserve.gov)
SEC SAB 122 rescinds SAB 121 (effective Jan 30, 2025). (sec.gov)
Dencun (EIP‑4844) mainnet activation, fee impact focused on L2s. (blog.ethereum.org)
ERC‑4337 references and mechanics. (eips.ethereum.org)
Circle Programmable Wallets: MAW pricing, Gas Station (5% fee), MPC hosting choices, and Compliance Engine (travel rule, screening). (circle.com)
Coinbase Embedded/Server Wallets: TEE key handling, KYT controls, op‑based pricing. (coinbase.com)
Fireblocks: SOC 2/ISO posture and MPC‑CMP open‑source; Notabene travel rule integration. (trust.fireblocks.com)
BitGo: TSS MPC model; OCC conditional national trust conversion (Dec 2025). (developers.bitgo.com)
FIPS 140‑3 options: AWS KMS/CloudHSM validations and guidance. (csrc.nist.gov)
EU: MiCA/DORA timeline confirmation; EBA travel rule guidelines (effective Dec 30, 2024). (finance.ec.europa.eu)