Over the past several months, we’ve had conversations about Fireblocks Trust Company with registered investment advisors (RIAs) and venture capital firms that follow the same arc. RIAs that are focusing on crypto are looking for qualified custodians that can support all of the assets in their portfolios; not just ETFs and proof of stake assets, but tokenized real estate, securities and more.
In their search for a qualified custodian, they hit the same wall: custody that satisfies their regulatory obligations with operational flexibility their strategies require.
For RIAs, that means meeting the SEC’s Custody Rule while still being able to access tokenized products, staking, and alternative digital asset strategies their clients are demanding. For VCs, it means protecting LP interests during token vesting periods while maintaining the governance participation and treasury management their portfolio companies need.
Let’s take a closer look at what qualified custody enables specifically for RIAs and VCs, including the regulatory framework, the practical challenges, and how firms are solving them today.
The regulatory landscape has shifted
The SEC’s Custody Rule (Rule 206(4)-2) mandates that RIAs that have custody of client funds maintain those funds with a qualified custodian to safeguard funds and mitigate risks. In September 2025, the SEC issued a no-action letter that provides clarity on how advisers may custody digital assets within the existing regulatory framework.
This matters for a practical reason: RIAs now have regulatory clarity to work with custodians like Fireblocks Trust Company, LLC — a limited-purpose trust company chartered under New York Banking Law and regulated by the New York State Department of Financial Services (NYDFS) — without the ambiguity that previously made compliance officers uncomfortable.
The regulatory pathway exists, and financial advisors’ crypto allocations are on the rise with a record 32% investing in crypto in client accounts in 2025. In fact, that same research from Bitwise shows that RIAs are the most likely investor type to allocate crypto to client accounts (over 40%). The time is now to lay the foundation to offer digital asset strategies while the opportunity is still early.
Bakkt’s clients seek out partners who refuse to compromise on security By utilizing Fireblocks Trust Company LLC, we marry world-class technical innovation with the elite oversight of a New York-chartered trust This partnership extends beyond simple key management; it provides a sophisticated governance framework that satisfies the most stringent institutional requirements. We are proud to work with a provider that shares our dedication to regulatory integrity, ensuring our clients can navigate the digital asset landscape with total certainty.
sam auch
Vice President, Head of Client Success & Partnerships, Bakkt
What RIAs need: custody that creates new investment strategies
At Fireblocks we know firsthand how custody decisions can unlock new business growth for institutions engaging with digital assets. The custody infrastructure you choose determines which digital asset strategies you can offer clients.
Here’s what we hear from RIAs evaluating qualified custody:
“My clients want exposure to digital assets, but my current custodian doesn’t support them.” This is the most common starting point. RIAs use a custodian for traditional assets, but those traditional custodians are still building digital asset capabilities, and most aren’t able to provide custody for digital assets yet. RIAs need a custodian that’s purpose-built for digital assets and meets the regulatory standards their compliance obligations demand. Fireblocks Trust delivers secure, compliant custody for any type of digital asset with bank-grade controls and protections.
“I want to access DeFi and offer tokenized alternatives, but I can’t find compliant custody for these products.” Tokenized private credit, real estate, and alternative investments are creating new opportunities for RIAs to differentiate. But these products require a custodian that supports both tokenized securities and RWAs, as well as crypto-native assets. In addition, DeFi lending pools are offering institutions a way to generate returns that simply didn’t exist through traditional custody channels. The custodian’s role is to make DeFi accessible, compliant, and safe for institutional capital. As a limited-purpose trust company under New York Banking Law, Fireblocks Trust can custody tokenized securities alongside digital assets. In other words, RIAs don’t have to wait for traditional custodians to catch up or accept solutions that don’t meet compliance standards. And as DeFi continues to evolve beyond crypto to stablecoins and tokenized RWAs, the institutions that figure out how to access DeFi yield safely and compliantly via a qualified custodian like Fireblocks Trust will have a structural advantage over those that sit on the sidelines.
“I need staking capabilities for crypto products and proof-of-stake assets, but I can’t sacrifice custody compliance.” Staking represents real yield for client portfolios, but it introduces operational complexity that seems at odds with qualified custody’s security requirements. The solution is policy-controlled staking executed directly from qualified custody accounts through established validators. We’ve built this through our partnership with Figment to enable RIAs to offer staking yield without stepping outside qualified custody.
What VCs need: protecting LP capital while maintaining operational control
VCs investing in blockchain protocols and token-based projects face a specific tension: LP agreements and fiduciary duties often require that portfolio tokens are held on a fully segregated basis, particularly during vesting periods. At the same time, VCs need operational flexibility to participate in governance votes, manage airdrops, coordinate token distributions, and execute treasury strategies.
Fireblocks Trust offers operational efficiency without compromise. VCs can hold a diverse range of digital assets on a bankruptcy-remote basis, with the flexibility to expand asset coverage as your business and investment needs evolve. Assets can be monitored across custody models via a single interface, eliminating the complexity of fragmented views and cross-platform integrations.
Castle Island Ventures is a good example of how this works in practice. They use qualified custody through Fireblocks Trust when LP agreements or fiduciary requirements demand it.
As a venture capital firm responsible for protecting our stakeholders’ investments, regulatory compliance and security are non-negotiable. Fireblocks Trust Company delivers on both fronts with their qualified custodian status and robust operational controls. The connectivity to the Fireblocks Network, leveraging the same experience we are used to with our self-custody wallet, has been a crucial and important differentiator, and has simplified our operations between the two treasury worlds.
matt walsh
Founding Partner, Castle Island
Here’s what this looks like for common VC scenarios:
Portfolio diversification across asset types
VCs increasingly hold a mix of liquid tokens, vesting positions, stablecoins, and tokenized equity. Managing these across multiple custodians creates reconciliation complexity and reporting gaps. A single platform that supports qualified custody and self-custody for different asset classes simplifies portfolio management significantly.
LP reporting and audit readiness
LPs expect institutional-grade reporting on custodied assets, and funds managing digital asset portfolios need accurate NAV reporting with transparent fund accounting. Fireblocks Trust provides the segregation, governance controls, and audit-ready documentation that fund administrators and LPs require without forcing VCs to build custom reporting infrastructure. In partnership with TRES, LP-ready NAV calculations across your entire portfolio are delivered daily for enhanced visibility. Audit-ready financials are available via connection with any ERP, and support for any accounting standard eliminates reconciliation delays.
Staking from qualified custody
For VCs holding proof-of-stake tokens, staking represents meaningful yield that LPs expect funds to capture. But staking has traditionally sat outside the qualified custody framework, forcing firms to choose between earning rewards and maintaining fiduciary-grade protections. Fireblocks Trust solves this through end-to-end staking management with policy-controlled validator access through providers like Figment. VCs can stake assets directly from qualified custody accounts, earn rewards, and access comprehensive reporting for tax services on staking rewards and asset liquidations. No movement to separate wallets, no gaps in custody coverage.
Fund structure compliance
Whether you’re a 3(c)(1) or 3(c)(7) fund, your custody arrangements need to meet the requirements of your fund documents and applicable regulations. Qualified custody with proper segregation and bankruptcy-remote structures gives fund counsel and compliance teams confidence that custody obligations are met.
Token Generation Events (TGEs) and vesting
When a portfolio company launches tokens, VCs need a qualified custodian to hold those tokens during vesting periods, particularly when institutional LPs require it. Fireblocks Trust supports custody during vesting while maintaining the flexibility for VCs to participate in governance and claim distributions as vesting schedules allow.
What to evaluate when choosing a qualified custodian
The ecosystem forming around qualified custody is one where assets aren’t just held and stored, but where custody integrates with the trading, lending, and operational infrastructure institutions already use. For RIAs and VCs evaluating custody partners, the breadth of that ecosystem matters. The more counterparties, prime brokers, and service providers connected to your custodian’s network, the more efficiently you can operate.
If you’re an RIA or VC evaluating qualified custody for digital assets, here are the questions you should be asking:
Regulatory standing and oversight
Is the custodian regulated as a qualified custodian under applicable law? Fireblocks Trust is chartered as a limited-purpose trust company under New York Banking Law and supervised by NYDFS.
Digital asset coverage
Can the custodian support the specific assets your strategy requires? Not just Bitcoin and Ethereum, but the tokens, stablecoins, tokenized securities and real-world assets your clients or LPs are exposed to. Custody that limits your asset universe limits your strategy.
Operational flexibility
Does qualified custody mean losing access to staking, governance, or treasury management? It shouldn’t. Look for custody that enables these capabilities through policy-controlled frameworks rather than restricting them entirely.
Integration with your existing workflows
Can you operate between qualified custody and self-custody on the same platform? Can you access unified reporting? Does the custody infrastructure connect to the counterparties and prime brokers you already work with?
Security infrastructure
Fireblocks Trust is built on the same defense-in-depth security architecture that protects over $10 trillion in digital assets across 2,400+ institutions. Cold storage custody, MPC-based key management, and air-gapped transaction signing provide institutional-grade protection.
Pathway to scale
Your custody needs today won’t be your custody needs in 18 months. The infrastructure should support your current strategy while adapting as your digital asset business grows from single-purpose custody to collateral management, staking, lending, and beyond.
The window is open
The regulatory clarity that RIAs and VCs have been waiting for is here with a workable framework in the US. The infrastructure, the regulatory oversight, and the ecosystem connectivity exist.
The institutions moving now are building advantages that will compound. RIAs who launch digital asset offerings are building client relationships and AUM in a market that’s still early. VCs who solve custody for portfolio tokens are participating in deals and governance opportunities that competitors without the right infrastructure can’t access.
The reality is that custody infrastructure is a prerequisite. You can’t offer staking yield to clients, custody LP tokens during vesting, launch tokenized products, or integrate with prime brokerages if you haven’t solved custody first.
If you’re an RIA or VC building a digital asset strategy, connect with the Fireblocks Trust team to discuss how qualified custody fits your specific requirements.
