VASP registration and banking for a digital-asset treasury

The brief

A family office allocating to digital assets was running exposure through the same entity as an operating trading firm. Banks were uncomfortable, counterparties were confused, and the source-of-funds narrative mixed two unrelated histories.

• Treasury and trading had to be genuinely separate entities with separate counterparties.
• The source-of-funds file had to reconstruct a decade of asset history to a bank's standard.
• Registration jurisdiction had to be one that banks would accept, not merely the fastest to obtain.
• Custody arrangements had to satisfy both the bank and the family's own risk committee.

How it was built, in order

1. 01
   Separation first

   Split treasury from trading before approaching any bank, because no bank was going to underwrite the combined story.

2. 02
   Jurisdiction chosen for bankability

   Selected the registration jurisdiction by asking banks what they would accept, not by processing speed.

3. 03
   Source-of-funds reconstructed

   Ten years of asset history assembled into a single file with exchange records, on-chain evidence and tax filings cross-referenced.

4. 04
   AML programme built

   Policies, MLRO appointment, transaction monitoring and travel-rule handling implemented before registration was granted.

5. 05
   Two banks, in parallel

   Applied to both simultaneously with the same file so a single declined application would not stall the mandate.

6. 06
   Custody and limits

   Qualified custodian appointed and written policy limits agreed with the family risk committee.