Custody of cryptocurrency in transit or in storage poses some specific risks that differ somewhat from the usual high-value small sized items, like jewelry. Cash in Transit (CIT) service providers will have to adjust security routines to take these differences into account.
By definition, providing transportation or storage of crypto means that it is in “cold” storage, meaning that it is offline — there is an air gap between the crypto and the Internet or some other digital network. Given that cryptocurrencies are always stored in digital files means that access to them is controlled via strongly encrypted “private keys” using 128-bit encryption generated by a “wallet” (a storage file).
Some risks carriers and vaults must take into account for secure custody of crypto include:
1. Items in custody come in small, somewhat fragile packages.
Even if the digital asset is worth millions of dollars, it can reside on a device the size of a thumb drive. The private key may be written on a piece of paper. Obviously, either of these would be easy to slip into a pocket, and neither weighs more than a few ounces. Packaging and handling have to take into account how easily these items can be damaged, as well as maintain an absolute lack of description of the contents to the casual observer.
2. The device is vulnerable.
The digital asset that the CIT or vault provider is responsible for will reside on some kind of electronic device that is capable of memory, and has a way to input the private key. The binary code that describes the asset contains its value, as well as the identity of its private key. Both of these are critical to access the value, and if either is lost, the value is permanently gone—it will be impossible to recover. Devices like this may be vulnerable to electronic or magnetic disruption, either by accident or intention, so CIT services have to be sure the files are not exposed to damaging fields.
3. The identity of the asset owner may be unknown.
Digital currencies were created in the first place to do away with the need for the regulations and controls imposed on fiat currencies like the US dollar. One standard control on ordinary currencies is the Know Your Customer(KYC) requirement. For crypto, where anonymity is a design feature, not a flaw, the custodian has the potentially large liability for criminal or terrorist activity if it does not know something about the identity of the asset owner(s). This information will have to come through procedures, not regulation requirements.
4. The carrier may not know the value of the currency they are responsible for.
Crypto carriers know Anti Money Laundering (AML) requirements, such as suspicious activity reporting, for values of any size. If custodial procedures depend in part on the value of the item, then determining that value is a critical matter. Beyond the ability of an owner to insure the item (whose risks must be known), the custodian is exposed to loss based on the value. This is a precarious situation.
5. Crypto requires unique access procedures that the custodian may need to help facilitate.
Custody of crypto means that there will always be two entities to protect: the digital file containing the currency, and a record of the private key, which may be physical. Since these two items can never be carried or stored in the same place, all of the risks described above apply to two complimentary assets that have to be brought together to access the value in the currency. This in itself creates the need for procedures to coordinate access in a way that ordinary items do not.
In general, custody of digital currencies takes place outside the financial system framework that regulates business as usual in CIT businesses. For more information about the sources of risks of crypto and policies for addressing them, see our new white paper, Custodial Crypto: Transportation and Storage.
