Updated

GL-C-05

Glossary · Banks and finance

Custodial wallet

Full glossary
keyswho holds them — the main question
2 modelscustodial and non-custodial
track recordwhat a regulated service provides

01 / In 30 seconds

The short answer

What it is
A wallet in which the private keys are managed by the service, not by you
The opposite
A non-custodial wallet: the owner holds the keys, with full control and full responsibility
The advantage of custodial
Convenience, recovery of access, support
Drawback
You depend on the reliability and solvency of the service
For compliance
A regulated service provides a documented transaction history — this matters

02 / In plain words

What Custodial wallet means

A custodial wallet is a store of crypto assets in which the private keys are managed by the service provider. You log in with a username and password, while actual control over the keys lies with the platform. The opposite model is a non-custodial wallet, in which the owner keeps the keys and no one else has access.

Each model has its own risk logic. The custodial option is convenient: access can be recovered, there is support, and you do not have to solve the problem of storing keys securely yourself. But you depend on the reliability, integrity and solvency of the service. The non-custodial option gives full control but also full responsibility: losing the keys means losing the assets irretrievably.

A separate aspect matters for our purposes. A regulated custodial service with full client identification leaves a documentary trail: transaction history, confirmations, statements. When evidencing the source of funds this is fundamental: the bank or programme reviewer wants to see documents, not screenshots. Assets that have passed only through anonymous wallets are considerably harder to explain.

A case from practice

When preparing a client’s dossier, some transactions had gone through a regulated platform and some through anonymous wallets. The first part was evidenced by exports and statements; the second had to be explained indirectly and took considerably longer.

When it matters

  • Storing crypto assets
  • Proof of source of funds
  • Converting into ordinary money
  • Succession planning
  • Opening a bank account
  • Preparing a file on your capital

03 / What it covers

What is compared

01

Custodial

  • The service holds the keys
  • Recovery of access
  • Support and convenience
02

Non-custodial

  • The owner holds the keys
  • Full control
  • Full responsibility
03

Risks

  • Reliability of the service
  • Loss of keys
  • Regulatory restrictions
04

Compliance

  • Documented history
  • Client identification
  • Statements for the bank

04 / How it works

How to choose and use one

Step 1

Define the storage task

Step 2

Check the service’s status

Step 3

Set up security

Step 4

Keep the transaction history

Step 5

A ready dossier if needed

05 / Key facts

What you need to know

01

In the custodial model the service manages the keys

02

In the non-custodial model the loss of keys is irreversible

03

A regulated service provides a documented history

04

Banks look closely at the source of crypto assets

05

Heirs’ access needs to be thought through separately

Common mistakes

  • Keeping large sums with an unregulated service
  • Not keeping the transaction history and confirmations
  • Not thinking through heirs’ access
  • Ignoring two-factor authentication
  • Expecting to explain the source of assets verbally

06 / Expert advice

Robert Haas

How to prepare in advance

If crypto assets are part of your capital, work through regulated platforms with full identification: they leave the documentary trail the bank will require. Keep the transaction history from the very start. And think through heirs’ access separately — in this sphere, losing access means losing the asset.

What we do for you. We advise clients with crypto assets to keep their capital with regulated providers and to keep the transaction history. This is not about distrust of the technology — it is about the fact that evidencing the source of funds requires documents.

Robert HaasHead of Company Formation

07 / Questions

Frequently asked questions

In a custodial wallet the service manages the private keys; in a non-custodial one, you do. Hence the different risk models.

There is no single answer. In one case you depend on the reliability of the service, in the other on your own discipline in storing the keys.

It carries out identification and leaves a documentary trail: the transaction history and statements that the bank and the programme check will require.

In the non-custodial model, access to the assets cannot be recovered. In the custodial model there is usually a recovery procedure through the service.

In advance: arrange access and record instructions for the heirs. Without this, the assets may be lost irretrievably.

With a confirmed history from the source of income to conversion — as a rule, yes. Without documents — almost certainly not.

Author: Robert Haas

Reviewed by: Sergej Evdokimov

Sources: FATF — on virtual assets

INITIAL ASSESSMENT

Tell us what outcome your family needs

We will design a solution for your case, choose the country and the right status, and take the whole process through to the result.

Or message us on WhatsApp or Telegram

Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice