Financial Services · Moraph software

Crypto-Asset Custody Bridge

Offer digital asset custody through sub-custodians while your bank keeps the ledger of record

Overview

What you are buying

The Crypto-Asset Custody Bridge sits between your bank and the sub-custodians that hold digital assets for your clients. Your bank keeps the legal ledger of record for each client's positions, client instructions go through maker-checker approval and compliance checks before they are sent to the sub-custodian, and positions are reconciled with the sub-custodian's records every day. Moraph does not hold assets, private keys or funds; the sub-custodian holds the assets under its agreement with your bank.

The problem it solves

Banks that want to offer digital asset custody usually rely on a specialist sub-custodian to hold the assets and keys, but the bank still owes its clients an accurate record of what they own and evidence that every movement was authorized and checked. Without a layer of their own, banks end up depending on the sub-custodian's portal for their books, approving withdrawals by email, and reconciling positions in spreadsheets. Examiners then ask how the bank oversees the sub-custodian and how it would know if the records did not match.

  • The bank's record of client positions depends on the sub-custodian's portal
  • Withdrawal and transfer approvals happen outside the bank's controls
  • Reconciliation between the bank's books and the sub-custodian's records is manual
  • Oversight of the sub-custodian is hard to evidence to examiners and the board

Who uses it

  • Banks and trust companies offering or planning digital asset custody
  • Custody and trust operations teams who process client instructions
  • Heads of digital assets and fiduciary officers who own the service
  • Compliance and BSA teams responsible for screening and recordkeeping
  • Third-party risk, internal audit and examiners who oversee sub-custodians

Requirements it supports

OCC Interpretive Letters 1170 and 1183 (crypto-asset custody by national banks)Interagency statement on crypto-asset safekeeping by banking organizations (2025)Interagency Guidance on Third-Party Relationships: Risk Management (2023)OCC fiduciary activities of national banks (12 CFR Part 9)Bank Secrecy Act recordkeeping and travel rule (31 CFR 1010.410)OFAC sanctions regulations (31 CFR Chapter V)

The product supports these requirements; meeting them remains your organization’s responsibility.

See how it works

A short walkthrough

Illustrative screens with fictional sample data. They show the workflow, not any client’s data or configuration, and the layout of the product itself differs. A live demonstration uses the product with sample data.

  1. Step 1

    Client positions

    The bank's ledger of record shows each client's positions by asset, with the sub-custodian account that holds them.

    Client accountAssetLedger positionSub-custodian accountLast reconciled
    Client 30418Bitcoin4.2500Example Sub-Custodian A, segregatedToday
    Client 30418Ether61.0000Example Sub-Custodian A, segregatedToday
    Client 52207Bitcoin0.8125Example Sub-Custodian A, omnibusToday
    Client 52207USD stablecoin125,000.00Example Sub-Custodian B, omnibusBreak open
    Client 71930Ether12.5000Example Sub-Custodian B, segregatedToday
    The bank's ledger of record shows each client's positions by asset, with the sub-custodian account that holds them.
  2. Step 2

    A withdrawal instruction

    Every check is shown on the instruction before the second approver decides.

    Client 30418 · Withdraw 1.5000 Bitcoin

    Entered by
    Operations analyst
    Destination
    Allowlisted address (sample) ...9f3a
    Balance check
    Sufficient
    Screening result
    Clear
    Travel rule information
    Attached
    Approval limit
    Above single-approver limit

    Checks

    • Address registered and verified for this client
    • Client mandate permits withdrawals to this address
    • Second approver required by policy
    Every check is shown on the instruction before the second approver decides.
  3. Step 3

    From instruction to confirmation

    The instruction's history shows who entered and approved it, when it was sent and when the sub-custodian confirmed it.

    Instruction IN-88412 · Client 30418

    1. Instruction entered from client requestOperations analyst
    2. Screening and travel rule checks attachedSystem
    3. Instruction approvedOperations approver
    4. Sent to Example Sub-Custodian ASystem
    5. Confirmation received and ledger updatedSystem
    The instruction's history shows who entered and approved it, when it was sent and when the sub-custodian confirmed it.
  4. Step 4

    Reconciliation breaks

    Each day's reconciliation lists differences between the ledger and the sub-custodian's records for operations to resolve.

    BreakClient accountAssetLedgerSub-custodianLikely causeAge
    BR-2291Client 52207USD stablecoin125,000.00124,000.00Pending withdrawal not yet confirmed1 day
    BR-2288Client 64015Ether3.00003.0021Unrecorded incoming transfer2 days
    BR-2284Client 30418Bitcoin4.25004.2500Resolved: timingClosed
    Each day's reconciliation lists differences between the ledger and the sub-custodian's records for operations to resolve.
  5. Step 5

    Approving a new address

    Adding a withdrawal address is a controlled change, verified and approved before it can be used.

    Client 71930 · New withdrawal address

    Address
    Sample address ...4c71
    Requested through
    Client portal
    Verification
    Call-back to client completed
    Screening result
    Clear
    Status
    Awaiting approval

    Before approval

    • Verification method recorded under your procedures
    • Address screened with your blockchain analytics tool
    • Requester and approver are different people
    Adding a withdrawal address is a controlled change, verified and approved before it can be used.
  6. Step 6

    Sub-custodian oversight

    The oversight file for each sub-custodian tracks reviews, reports and incidents for the board and examiners.

    Example Sub-Custodian A (fictional) · Oversight file

    1. Annual due diligence questionnaire receivedThird-party risk
    2. Control report reviewed; exceptions notedThird-party risk
    3. Late confirmation incident recordedOperations approver
    4. Exit plan updated with current positionsHead of digital assets
    5. Oversight review approvedHead of digital assets
    The oversight file for each sub-custodian tracks reviews, reports and incidents for the board and examiners.

Workflows

The principal workflows

  1. Onboard

    Client custody accounts are opened in the Bridge and mapped to the matching segregated or omnibus account at the sub-custodian, and each digital asset the bank supports is approved before clients can hold it.

    • Client account opened after the bank's own onboarding and due diligence
    • Account mapped to the sub-custodian account structure
    • Supported assets approved by the bank's committee with their risk assessment
    • Client's allowed withdrawal addresses registered and verified
    • Account activated for deposits
  2. Instruct

    Deposits, withdrawals and transfers are entered as instructions, checked against the client's mandate, allowlisted addresses and screening results, approved by a second person, and sent to the sub-custodian.

    • Instruction entered by operations or received from the client channel
    • Checks run: balance, mandate, allowlisted address and screening result
    • A second operations approver approves or rejects the instruction
    • Approved instruction sent to the sub-custodian through its interface
    • Sub-custodian confirmation recorded and the ledger updated
  3. Reconcile

    Every day, the bank's ledger is reconciled with the sub-custodian's positions and, where configured, with public blockchain balances for the addresses involved. Breaks are opened as items to investigate.

    • Sub-custodian positions and transactions loaded
    • Positions matched by client account and asset
    • Breaks created with the difference and likely cause
    • Operations investigate and resolve each break with a note
    • Unresolved breaks escalated to the head of digital assets
  4. Oversee

    The bank's oversight of each sub-custodian, from due diligence and control reports to incidents and exit planning, is recorded in one place for the board and examiners.

    • Due diligence and control reports collected on the bank's schedule
    • Service incidents and confirmations outside agreed terms recorded
    • Periodic oversight review completed and approved
    • Exit and contingency plan kept current with client positions
    • Board and committee reporting prepared

Roles and permissions

Who does what in the product

Each role below is a starting point. During implementation we set them up to match your teams, and every action anyone takes is recorded in the audit trail.

Custody operations analyst

Custody operations analyst, trust operations specialist, digital asset operations analyst

Processes client instructions and keeps the ledger reconciled with the sub-custodian.

Sees

  • Client accounts, positions and allowlisted addresses
  • Instructions they entered and their status
  • Reconciliation results and open breaks
  • Sub-custodian confirmations

Does

  • Enters deposit, withdrawal and transfer instructions
  • Opens accounts and requests address changes
  • Investigates and resolves reconciliation breaks with notes
  • Follows up unconfirmed instructions with the sub-custodian
  • Prepares client statements for review

Cannot

  • Approve their own instructions or address changes
  • Approve new assets or change limits
  • Release an instruction held by compliance checks
Approvals
Every instruction and address change they enter is approved by an operations approver before it takes effect.
Notified about
Instructions rejected or confirmed, new breaks assigned to them, and instructions waiting for sub-custodian confirmation.

Operations approver

Custody operations supervisor, trust operations manager

Provides the second check on every instruction and address change before it is sent or used.

Sees

  • Instructions and address changes waiting for approval, with their checks
  • Client accounts and positions
  • Reconciliation status and escalated breaks

Does

  • Approves or rejects instructions with a reason
  • Approves or rejects address changes
  • Reviews escalated reconciliation breaks
  • Records sub-custodian service incidents

Cannot

  • Approve an instruction they entered
  • Approve above their approval limit
  • Change the ledger directly
Approvals
Instructions above their limit go to the head of digital assets for a further approval.
Notified about
Instructions and address changes waiting for approval, and breaks older than your procedures allow.

Head of digital assets

Head of digital assets, head of custody, fiduciary officer

Owns the custody service and its controls, approves assets and limits, and answers for sub-custodian oversight.

Sees

  • Every account, position, instruction and break
  • Sub-custodian oversight files
  • Asset approvals and limit settings
  • The full audit trail

Does

  • Approves new supported assets with their risk assessment
  • Sets approval limits and maker-checker rules
  • Approves instructions above operations limits
  • Approves periodic sub-custodian oversight reviews
  • Maintains the exit and contingency plan
  • Reports to the board and committees

Cannot

  • Enter and approve the same instruction
  • Edit or delete entries in the audit trail
  • Change a confirmed instruction
Approvals
Approves assets, limits, large instructions and oversight reviews; changes they propose to limits need a second senior approver.
Notified about
Instructions above operations limits, breaks escalated, sub-custodian incidents and oversight reviews coming due.

Compliance officer

BSA officer, compliance officer, financial crimes analyst

Makes sure instructions carry the screening and travel rule information the bank needs, and decides on any that are held.

Sees

  • Instructions held by screening or travel rule checks
  • Screening results for accounts and addresses
  • Travel rule records for each transfer
  • Client account activity

Does

  • Reviews held instructions and releases or rejects them with a reason
  • Reviews address screening results
  • Refers activity to the bank's AML investigation process
  • Reviews recordkeeping reports

Cannot

  • Enter or approve instructions
  • Change positions or reconciliations
  • Approve assets or limits
Approvals
Their decision is required before a held instruction can proceed to operations approval.
Notified about
Instructions held by checks and addresses with screening alerts.

Auditor or examiner (read-only)

Internal auditor, external auditor, regulatory examiner (under temporary access)

Reviews the custody service's records and controls without being able to change anything.

Sees

  • The ledger, instructions and approvals within the scope granted
  • Reconciliations and breaks
  • Sub-custodian oversight files
  • The audit trail

Does

  • Searches and reads records within their scope
  • Exports records and reports, with each export logged
  • Leaves review notes where the bank enables them

Cannot

  • Change, approve, send or delete anything
  • See records outside the scope and dates granted
  • Keep access after it expires
Approvals
Their access is approved by the head of digital assets or an administrator, with a scope and an end date.
Notified about
Nothing by default; access granted and expiring is confirmed to the person who approved it.

Administrator

Application administrator, operations systems administrator

Manages users, roles and connections on behalf of the custody team, without any ability to move assets.

Sees

  • Users, roles and approval limits assigned
  • Sub-custodian and tool connection status
  • The record of permission changes

Does

  • Adds and removes users, or maps them from single sign-on groups
  • Assigns roles
  • Monitors connections and resolves errors
  • Runs access review reports

Cannot

  • Enter, approve or send instructions
  • Change the ledger, addresses or limits
  • Grant themselves an operations role without the head of digital assets
Approvals
Role changes that grant entry or approval rights are approved by the head of digital assets.
Notified about
Connection failures, access reviews coming due and accounts not used for a period your policy sets.

Permissions at a glance

ActionOps analystOps approverHead of assetsComplianceAuditorAdmin
Open client custody accountsFullApprovesFullView onlyView onlyNo access
Enter instructionsFullNo accessNo accessNo accessNo accessNo access
Approve instructionsNo accessApprovesApprovesNo accessNo accessNo access
Release held instructionsNo accessNo accessNo accessFullView onlyNo access
Add or change withdrawal addressesFullApprovesApprovesView onlyView onlyNo access
Resolve reconciliation breaksFullFullFullNo accessView onlyNo access
Approve supported assetsNo accessNo accessApprovesView onlyView onlyNo access
Set approval limits and rulesNo accessNo accessApprovesNo accessView onlyNo access
Maintain sub-custodian oversight fileNo accessOwn work onlyFullView onlyView onlyNo access
View ledger of recordView onlyView onlyView onlyView onlyView onlyNo access
View audit trailNo accessNo accessView onlyView onlyView onlyView only
Manage users and rolesNo accessNo accessApprovesNo accessNo accessFull
  • Full
  • Own work only
  • Approves
  • View only
  • No access

How access is controlled

  • Maker-checker rules are built in: nobody approves an instruction, address change or limit change they entered, and administrators can neither enter nor approve instructions.
  • Roles are configured with you during implementation. You can rename them, add roles such as a third-party risk reviewer, and set approval limits by person, asset or instruction type.
  • Every permission change is recorded in the audit trail with who made it and when, and access review reports list each person's roles and limits for periodic certification.
  • Staff sign in through your identity provider, and roles can follow its groups. Auditors and examiners get temporary read-only access with a defined scope and an end date, rather than shared accounts.

Features

What it does

Ledger of record

The bank's own record of each client's positions by asset and account, updated only from confirmed instructions and kept independent of the sub-custodian's portal.

Maker-checker instructions

Every withdrawal and transfer is entered by one person and approved by another before it is sent, with limits your policy sets.

Address allowlisting

Withdrawals go only to addresses registered for the client and verified under your procedures, with changes subject to approval.

Pre-send compliance checks

Instructions are held until screening and travel rule information from your compliance tools are attached and clear.

Daily reconciliation

Positions reconciled with the sub-custodian's records, and optionally with public blockchain balances, with breaks tracked to resolution.

Sub-custodian connections

Instructions and confirmations exchanged with supported sub-custodians through their interfaces, with a manual path when an interface is unavailable.

Asset approval

Each supported asset is approved by your committee with its risk assessment, and clients can hold only approved assets.

Account segregation mapping

Each client account is mapped to segregated or omnibus accounts at the sub-custodian, so the bank can show which client owns what.

Client statements

Periodic statements of positions and activity produced from the ledger of record, with values from the pricing source you choose.

Sub-custodian oversight file

Due diligence, control reports, insurance evidence, incidents and review outcomes for each sub-custodian, kept for the board and examiners.

Exit and contingency planning

A current record of client positions by sub-custodian account, ready for transfer to another custodian if the relationship ends.

Exam-ready audit trail

Who entered, approved, sent, reconciled or changed what, and when, for every instruction, account and asset.

Integrations

How it connects to your systems

Connects toHowWhat flows
Sub-custodiansInstructions, confirmations, positions and transactions exchanged with each supported sub-custodian through its interface, confirmed during implementation.Out: approved instructions. In: confirmations, positions and transactions.
Core banking and trust accountingClient and account records, fees and cash movements related to custody, so digital asset accounts sit alongside the client's other relationships.In: client and account records. Out: positions and activity for statements and accounting.
Sanctions and blockchain analytics screeningResults from the screening and blockchain analytics tools your bank uses, attached to accounts, addresses and instructions.In: screening results and risk scores for addresses and counterparties.
Travel rule messagingOriginator and beneficiary information exchanged through the travel rule solution your bank uses, attached to each transfer.In and out: travel rule information for each transfer.
Pricing sourceAsset prices from the provider you choose, used for statements and reporting.In: end-of-day prices by asset.
Single sign-onStaff sign in through your identity provider (SAML or OpenID Connect).In: user identity and group membership for role assignment.
Work APILedger, instruction and reconciliation data available to your data warehouse and reporting tools through the Moraph Work API.Out: positions, instructions, breaks and approvals.

Each integration is confirmed in discovery and specified in the design. See how an engagement progresses.

Security and privacy

How your data is protected

Single sign-on

Staff sign in through your identity provider, so your password and multi-factor policies apply.

No keys or assets at Moraph

The Bridge never holds private keys, digital assets or funds. Assets and keys stay with the sub-custodian under its agreement with your bank.

Role-based access

Entering an instruction is separate from approving it, and administrators cannot do either.

Encryption and keys

Client data is encrypted, with keys Moraph staff cannot use without explicit, time-bound authorization.

Complete audit trail

Every view, change, instruction, approval and export is logged with the person and time, and cannot be edited.

Data residency

Data stays in the hosting region you choose: the United States, the United Kingdom or Australia.

Company-wide controls, independent audits (SOC 2 Type II and ISO/IEC 27001) and data residency are described in our Trust Center, where you can request the evidence pack.

Reporting

What you can report on

11 standard reports, grouped by who uses them. Each shows who it is for, how it can be broken down, how it is delivered and what it is used for. The data behind them is also available to your own reporting tools.

Operational

Instruction status

For operations analysts and approvers

Every instruction with its checks, approvals, sending time and confirmation, open items first.

Break down by
Status, Instruction type, Asset, Sub-custodian, Entered by
Delivered as
Live dashboard; CSV export
Used for
Making sure every instruction is approved, sent and confirmed.

Reconciliation breaks

For operations analysts, approvers and the head of digital assets

Open and resolved breaks with the difference, likely cause, age and resolution note.

Break down by
Sub-custodian, Asset, Cause, Age band
Delivered as
Live dashboard; scheduled email; CSV export
Used for
Resolving differences between the bank's ledger and the sub-custodian's records.

Held instructions

For compliance officers

Instructions held by screening or travel rule checks, with the reason held and the decision taken.

Break down by
Reason held, Decision, Asset, Period
Delivered as
Live dashboard; CSV export
Used for
Deciding held instructions promptly and evidencing each decision.

Management and board

Assets under custody

For head of digital assets, senior management and the board

Client positions and values by asset, account type and sub-custodian.

Break down by
Asset, Sub-custodian, Account type, Period
Delivered as
PDF; live dashboard; CSV export
Used for
Understanding the size and concentration of the custody business.

Sub-custodian oversight summary

For head of digital assets, third-party risk and the board

For each sub-custodian, the status of due diligence, control reports, incidents, open findings and the exit plan.

Break down by
Sub-custodian, Review area, Status
Delivered as
PDF; scheduled email
Used for
Showing the board how each sub-custodian is overseen.

Service activity

For head of digital assets and senior management

Accounts opened, instructions processed, rejections and breaks over time.

Break down by
Period, Instruction type, Asset, Sub-custodian
Delivered as
Live dashboard; CSV export
Used for
Planning staffing and spotting operational trends.

Regulatory and audit

Approval evidence

For internal audit and examiners

For selected instructions and address changes, who entered and approved them, the checks attached and the confirmation.

Break down by
Record type, User, Date range, Asset
Delivered as
On request in the product; PDF and CSV export
Used for
Evidencing that maker-checker and compliance checks operated on every movement.

Asset and limit change history

For head of digital assets, internal audit, examiners

Every asset approval, removal and limit change, with its risk assessment, approver and effective date.

Break down by
Asset, Change type, Approver, Change date
Delivered as
Live view; PDF and CSV export
Used for
Showing how the service's scope and controls were governed.

Travel rule records

For compliance officers and examiners

Originator and beneficiary information recorded for each transfer within the period.

Break down by
Period, Asset, Direction
Delivered as
Live view; CSV export
Used for
Answering recordkeeping requests.

Audit trail extract

For internal audit and examiners

Who did what, when and why for a selected account, instruction, address or period.

Break down by
Record, User, Action, Date range
Delivered as
On request in the product; CSV and PDF export
Used for
Answering examiner requests for evidence without assembling it by hand.

Client

Client statements

For clients, through your statement channels

Each client's positions, values and activity for the period, from the ledger of record.

Break down by
Client account, Asset, Period
Delivered as
PDF; file to your statement system
Used for
Giving clients an accurate record of what the bank holds for them.

Exports, access and evidence

  • Every report can be exported to CSV, and summary and evidence reports to PDF. Reports can be scheduled to arrive by email for the people entitled to see them.
  • Each report can be filtered and the filters saved. Reports that need a different shape can be built in your own tools from the data described below.
  • Ledger, instruction, reconciliation and oversight data is available through the Moraph Work API, and can be delivered to your data warehouse or business intelligence tool.
  • Reports respect each viewer's role: operations see the accounts they service, the head of digital assets sees the whole service, and examiners can be given read-only access.
  • Ledger and audit reports can be run as of a past date and give the same result each time. Running and exporting a report is itself recorded in the audit trail.

Deployment

Where and how it runs

Moraph cloud

Hosted and operated by Moraph in the United States region. United Kingdom and Australia regions are available for institutions outside the US.

Dedicated environment

A single-tenant environment for institutions whose policies require isolation, scoped in the proposal.

With a managed service

Optionally run alongside a Moraph managed service for sub-custodian connection monitoring and platform administration.

Security controls, independent audits and data residency are set out in our Trust Center. Engagement models and what drives a quotation are on Working with Moraph.

Implementation

What a rollout involves

The general phases are on Working with Moraph. For this product, they involve the following.

Operating model

We document how your custody service will run: account structures, supported assets, approval limits and the split of duties between your bank and each sub-custodian. We need your policies and a contact in operations and compliance.

Sub-custodian connection

Each sub-custodian's interface is connected and tested in its test environment, including confirmations and position files, before any live instruction is sent.

Compliance tool connections

Screening, blockchain analytics and travel rule tools are connected so instructions carry their results before approval.

Ledger opening balances

Where you already hold client assets through a sub-custodian, opening positions are loaded and reconciled with the sub-custodian before go-live.

Controls and roles

Maker-checker rules, approval limits, allowlist procedures and roles are configured to match your policies and tested with your team.

Training and go-live

Operations, compliance and approvers are trained on their own workflows, and the first live instructions are monitored together with your team.

Limitations

What it does not do

Worth knowing before you evaluate it.

  • Moraph does not hold digital assets, private keys or funds, and is not a custodian. Assets are held by the sub-custodian under its agreement with your bank.
  • Whether your bank may offer digital asset custody, and on what terms, is a matter for your bank and its regulators. The Bridge supports your controls; it does not grant permission to offer the service.
  • It works only with sub-custodians whose interfaces are supported; others can be added by agreement after review.
  • It does not perform sanctions screening, blockchain analytics or travel rule messaging itself. It uses the results of the tools your bank already has.
  • It does not execute trades or provide access to exchanges or liquidity providers.
  • Staking, lending and other activities beyond safekeeping and transfer are not included.
  • Reconciliation depends on the sub-custodian supplying complete and timely position and transaction data.
  • It does not provide accounting or tax treatment of digital assets; your finance team determines how they are recorded.

Evaluation checklist

What to test in a demonstration or pilot

Questions worth putting to us, and to any other vendor you are considering.

  1. Walk a withdrawal from client request to sub-custodian confirmation and check every control along the way
  2. Load a sample position file from your sub-custodian and review the reconciliation and breaks
  3. Confirm that nobody can both enter and approve the same instruction or address change
  4. Check how screening and travel rule results from your existing tools attach to instructions
  5. Review the sub-custodian oversight file against what your examiners have asked for
  6. Confirm how client positions would be produced for transfer if a sub-custodian relationship ended

Questions

Frequently asked questions

Does Moraph hold our clients' digital assets or keys?

No. Moraph does not hold digital assets, private keys or funds. The sub-custodian holds them under its agreement with your bank, and the Bridge keeps your bank's record and controls.

Which sub-custodians does it work with?

The sub-custodians supported are confirmed during scoping. Others can be added by agreement once their interface and controls have been reviewed.

Who owns the data in the Bridge?

Your bank does. How it is returned to you and deleted at the end of the agreement is set out in the contract.

How is it priced?

As a subscription, usually measured by the number of client accounts and sub-custodians connected, with implementation charged separately. See Working with Moraph for what drives a quotation.

How do examiners see our controls?

A read-only examiner role shows the ledger, instructions with their approvals, reconciliations, sub-custodian oversight and the audit trail, and everything can be exported.

Is there an accessibility conformance report?

Ask for one through the procurement request form at /how-to-buy/request, naming the version you are evaluating.

Next steps

Evaluate Crypto-Asset Custody Bridge

Buying through a formal procurement? See How to buy for purchasing routes, accessibility conformance reports and company information. Documentation: Crypto-Asset Custody Bridge guides on docs.moraph.com (getting started and security guides are public; setup, administration and integration guides are for client accounts). Support: Crypto-Asset Custody Bridge support guide.