Custody models & services

Beginner Intermediate Expert

"Not your keys, not your coins" is true — but holding every key alone is also a risk. Between full self-custody and handing everything to an exchange sits a spectrum of models. Choose consciously.

Last fact-checked 24 October 2026 (time-sensitive claims re-checked against the linked sources).

Exchange or self-custody? The basics Beginner

If you hold coins on an exchange or app, the firm holds the keys and you hold a claim against the firm. If you hold your own keys (for example on a hardware wallet), nobody can freeze or lose your coins for you, but nobody can get them back for you either. The FTC puts it plainly: if your exchange goes out of business, you lose your password or your wallet is compromised, "no one can step in to help you recover your funds" (FTC).

QuestionOn an exchangeSelf-custody
Who holds the keysThe firmYou
Main risksFirm failure, fraud, account freezes, hacks of the firmLosing the backup, theft of the backup, scams, mistakes when sending
If you forget a passwordUsually recoverable through the firmOnly your own backup can help
On your deathExecutors deal with the firmHeirs need your plan; see estate planning

Many people use both: a small amount on an exchange for trading, and longer-term savings in self-custody. Sparrow Wallet's best-practice guide, which this site treats as community advice, suggests moving from simpler single-signature set-ups to multisig as holdings grow (Sparrow).

Exchange or self-custody: what protects you in the UK and USA Beginner Intermediate

Bank deposits come with a safety net. Crypto held for you by a company usually does not, and crypto you hold yourself never does: if you lose your keys, the SEC warns, "you permanently lose access" (SEC Investor Bulletin, 12 December 2025). The table sets out where UK and US readers stand. For the compensation details, see UK vs USA on the compare page.

QuestionUnited KingdomUnited States
Is my exchange balance protected if the firm fails?Generally not. The FSCS says the FCA "does not regulate most cryptoassets, so FSCS cannot protect you if a platform that exchanges or holds them goes out of business" (FSCS). The FSCS only pays out when an authorised firm fails while carrying out a regulated activity (FSCS eligibility).Generally not. The FDIC lists crypto assets among the products it does not insure (FDIC). SIPC "does not protect any digital or crypto asset that does not qualify as a 'security'". Its page quotes the SEC and CFTC naming bitcoin and ether among examples of "digital commodities" (SIPC).
Can I complain to an ombudsman?Usually not. Report Fraud says most crypto activities are unregulated, so you will not have access to the Financial Ombudsman Service (Report Fraud).The SEC suggests researching a custodian before you deposit: search for complaints and find out how it is regulated (SEC).
If I am scammedReport to Report Fraud (England, Wales and Northern Ireland) or Police Scotland on 101, then the FCA. The FCA says it cannot help you get your money back (FCA).Report to the FBI's IC3 and the FTC at ReportFraud.ftc.gov.
Withdrawing to my own walletSince 1 September 2023, UK crypto firms have had to collect, verify and share information about transfers (the "Travel Rule"), so expect questions about withdrawals (FCA). US: FinCEN's "Funds Travel Rule" applies to transmittals of $3,000 or more, including crypto (31 CFR 1010.410(f); FIN-2019-G001); the 2020 unhosted-wallet proposal was withdrawn on 6 October 2026 (Federal Register).Self-custody means "sole responsibility" for your keys and seed phrase (SEC).
What is changing?A new FCA authorisation regime, covering safeguarding (custody), applies from 25 October 2027 (FCA). Check what a firm actually offers. Do not assume FSCS cover.The SEC's December 2025 bulletin lists questions to ask any custodian; see below.

Trade-offs in plain English Beginner

Exchange: pros

  • Forgotten passwords can usually be reset
  • Easy to buy, sell and cash out
  • Executors deal with a firm that has a bereavement process (see directory)

Exchange: cons

  • If the firm is hacked, shuts down or goes bankrupt, "you may lose access" (SEC)
  • No FSCS cover in the UK and no FDIC or SIPC cover in the US for ordinary crypto (sources above)

Self-custody: cons and pitfalls

  • Nobody can reset anything: a lost key or phrase means permanent loss (SEC)
  • Setting up "may require some technical savvy" (SEC)
  • You become the target for phishing and fake support (see safety)

Community advice (labelled: experience shared by users, not official guidance)

  • Community advice: a common pattern is a small spending balance on an exchange and long-term savings in self-custody, moved across in stages after a test restore
  • Community advice: whichever you choose, write down where things are for your executor (see letter of instruction)

Questions the SEC suggests asking a custodian Intermediate

These add to the custody-agreement questions below. They are paraphrased from the SEC's bulletin (SEC):

  • What is its background and complaint history, and how is it regulated?
  • Which assets can you hold there?
  • Does it hold assets in hot wallets, cold wallets or both, and does it subcontract storage to someone else?
  • Does it lend out customer assets ("rehypothecation") or mix them together ("commingling"), and does it need your consent?
  • What insurance applies to loss or theft, and on what terms?
  • What personal data does it keep, and does it sell any?
  • What fees does it charge?

Moving coins off an exchange safely, step by step Beginner Intermediate

  1. Set up and test first. Create and test-restore your wallet before moving anything (Start here, step 5).
  2. Secure the exchange account. Use a unique password and app-based or security-key two-factor authentication rather than text messages. The FBI recorded 1,611 SIM-swap complaints with more than $68 million in losses in 2021, and recommends authenticator apps, physical security tokens or biometrics (FBI/IC3). Turn on 2-step verification for your email as well: the NCSC lists email among your most important accounts (NCSC).
  3. Get the address from the device. Copy the receive address from your wallet's Receive screen and check it on the device's own screen, never from your transaction history (Ledger).
  4. Match the coin and network. Make sure the exchange's withdrawal screen shows the same coin and network that your wallet account uses. If you are unsure, stop and check the wallet maker's help pages.
  5. Send a small test. Wait until it shows in your wallet. Trezor's guidance on moving funds uses the same step (Trezor).
  6. Send the rest, then check the balance on your own wallet.
  7. Keep a record of the date, the amounts and the exchange so that your tax records show it was a transfer between your own accounts (see UK and US tax records).

Pros of moving in stages

  • A mistake costs only the test amount
  • You practise sending before a large transfer

Cons

  • Each withdrawal may carry a fee
  • UK exchanges may pause a transfer to ask Travel Rule questions (FCA); US exchanges apply FinCEN's Travel Rule to transfers of $3,000 or more (eCFR)

Pitfalls

  • Rushing because a call or message says your account is "at risk" (see the Coinbase impersonation case)
  • Leaving a forgotten balance behind. In the US, dormant accounts can be handed to a state as unclaimed property
  • Withdrawing to an address pasted from history or a chat

Community advice (labelled: experience shared by users, not official guidance)

  • Community advice: write down the first receive address and check it after any future restore
  • Community advice: if the amount would hurt to lose, do the test and the main transfer on different days so that you are not rushed

The custody spectrum Beginner

Solo self-custodySingle-sig, you hold everything
→
Self-custody, splitSLIP-39 / your own multisig
→
Collaborative custodyYou hold 2 of 3 keys, a firm holds 1
→
Multi-institutionKeys held by separate institutions
→
Full custodianExchange or qualified custodian
Left: maximum control and responsibility. Right: maximum convenience and counterparty risk.

Collaborative custody providers Intermediate

ProviderModelAssetsInheritanceNotes
Casa2-of-3 or 3-of-5 multisig; Casa holds one recovery keyBTC; ETH & stablecoinsIncluded; 6-month claim window; enhanced verification for private clients (docs)Subscription: Standard $250/yr (3-key vault), Premium $2,100/yr (5-key vault, hardware included), Private Client $7,500/yr (Casa pricing, checked 24 October 2026). Enhanced verification is US-only.
Unchained2-of-3; you hold two keysBTCInheritance Protocol, trust vaults, TOD beneficiaries (details)US-focused; also IRA products
NunchukSelf-managed multisig; optional assisted plans with platform keyBTCOn-chain timelock or assisted off-chain (details)No-KYC model
OnrampMulti-institution custody (2-of-3 across institutions)BTCVia account structureUS-focused; client holds no keys
AnchorWatchMultisig with optional insuranceBTCCheck offeringEligibility restrictions apply
Bitkey2-of-3: hardware + phone + Block serverBTCOne beneficiary, who needs their own Bitkey; a claim starts a 6-month delay you can cancel. Bitkey says a beneficiary setting does not override a will (Bitkey inheritance)Consumer-friendly; no seed words
Liana (software)Your keys + timelocked recovery keysBTCHeir key valid after inactivity periodOpen source; no company in the loop

Pros

  • Professional key management and support
  • Survive losing one of your keys
  • Structured inheritance

Cons

  • Recurring fees
  • Some KYC and data held by the firm
  • Jurisdiction and business-continuity risk

Common pitfalls

  • Not keeping your own copy of the wallet descriptor/config
  • Heirs who don't know the provider exists
  • Storing your two keys in the same building

Advice

  • Ask: "Can I recover without you if you disappear?" — with standard multisig and your descriptor, usually yes
  • Compare services independently (independent comparison)

Pros, cons and pitfalls by model Intermediate

Exchange or app custody

Pros

  • Simple; password resets and support
  • Easy to trade and cash out

Cons

  • Counterparty risk: you are a creditor if the firm fails
  • Freezes and withdrawal limits are at the firm's discretion

Pitfalls

  • Leaving long-term savings on a trading platform
  • Assuming crypto has FSCS-style protection; the FCA says it is "highly unlikely" you will be covered (FCA; see UK and USA)

Community advice (labelled: experience shared by users, not official guidance)

  • Community advice: if you leave funds on an exchange, use a unique password and app-based two-factor authentication, and test a withdrawal now and then

Solo self-custody (single-signature)

Pros

  • No third party can freeze or lose your coins
  • Low cost: one device and a metal backup (see price check)

Cons

  • One backup is a single point of failure for both loss and theft
  • No-one can reset anything for you

Pitfalls

  • Never testing a restore
  • Keeping the backup and device together

Community advice (labelled: experience shared by users, not official guidance)

Collaborative custody (you hold most keys)

Pros

  • Survive losing one key; professional help with inheritance

Cons

  • Subscription costs, for example Casa Standard at $250 a year (Casa)
  • Some identity data is held by the firm

Pitfalls

  • Not keeping your own copy of the wallet descriptor

Community advice (labelled: experience shared by users, not official guidance)

  • Community advice: before signing up, ask the provider how you would recover if it disappeared, and keep that answer with your records

Qualified and institutional custodians Expert

For companies, funds, trustees and some very large holders, regulated custodians (e.g. Coinbase Prime, Fidelity Digital Assets, Anchorage Digital, BitGo, Zodia Custody, Komainu) provide segregated custody, audits and reporting.

  • UK: check the FCA register for cryptoasset registration status. A new FCA authorisation regime, which covers safeguarding (custody) of cryptoassets, starts on 25 October 2027. The application window runs from 30 September 2026 to 28 February 2027, and existing money-laundering registrations do not convert automatically (FCA: new cryptoasset regime). Until then, registration is not the same as full FCA authorisation or FSCS protection.
  • US: look for state trust charters or federal charters; "qualified custodian" has a specific meaning under SEC rules for advisers.
  • EU: MiCA-authorised crypto-asset service providers (CASPs) — see EU notes.
  • Read the custody agreement for bankruptcy remoteness, insurance limits and what happens on the account holder's death.

What happens if a custodian fails Expert

Three real, sourced examples show why "who legally owns the coins" matters as much as security:

  • Celsius (2023). On 4 January 2023 the US Bankruptcy Court for the Southern District of New York ruled that crypto in Celsius "Earn" accounts had become Celsius's property under its terms of use, so it belonged to the bankruptcy estate and account holders were unsecured creditors (opinion (PDF)).
  • FTX (2022–2024). The US Department of Justice says Samuel Bankman-Fried misappropriated billions of dollars of FTX customer funds; he was sentenced to 25 years in prison in March 2024 (US Attorney, SDNY).
  • Coinbase disclosure (2022). In its quarterly report for the period to 31 March 2022, Coinbase warned that in a bankruptcy, custodially held crypto could be treated as property of the estate and customers could be treated as general unsecured creditors (Form 10-Q). That disclosure followed SEC Staff Accounting Bulletin 121, which the SEC rescinded with SAB 122 in January 2025 (SAB 122). The accounting change does not by itself change who owns the coins; read the custody agreement.

In the UK, the FCA's new cryptoasset regime, which covers safeguarding, starts on 25 October 2027 (FCA). Until then, check exactly what protection a firm claims to offer.

Questions for the custody agreement
  1. Are my assets segregated and held for me, or do they become the firm's property (as Celsius's terms did for Earn accounts)?
  2. Can the firm lend, stake or rehypothecate them?
  3. What happens to my assets if the firm becomes insolvent?
  4. What insurance applies, to what, and up to what limit?

Safe deposit boxes & private vaults Intermediate

Pros

  • Strong physical security off-site
  • Good home for one share or key

Cons

  • Opening hours, fees
  • Access may be frozen on death until probate (England & Wales) / confirmation (Scotland) or a court order (US)
  • Many UK high-street banks have withdrawn the service

Pitfalls

  • Putting a complete single-sig seed in a box held in your name only
  • Not telling executors the box exists

Advice

  • Use for a multisig key or SLIP-39 share; seal in a tamper-evident bag; record the bag serial

Solicitors, attorneys, escrow & professional trustees Intermediate

A solicitor (UK) or attorney (US) can hold sealed instructions or a single share as part of your estate plan, act as executor or trustee, or coordinate with a collaborative-custody provider. They should never hold everything needed to spend. Find specialists via STEP, the Law Society (England & Wales), the Law Society of Scotland, or ACTEC (US).

Questions to ask any adviser or service
  1. Have you handled crypto estates before? How many?
  2. Will you ever need my seed phrase? (Correct answer: no.)
  3. What happens if your firm closes or is acquired?
  4. Are you regulated, and by whom? What insurance applies?
  5. How do my heirs prove entitlement, and how long does it take?

Primary sources for this page

Listing is not endorsement. Educational information only, not financial or legal advice. Checked 24 October 2026.

Last reviewed: · Educational information only — verify current details with official sources.