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Digital Asset Recovery Regulatory Review

Regulatory expectations, mapped to recovery controls.

A jurisdiction-by-jurisdiction view of recovery, resilience, and evidence controls regulators expect for digital asset services.

Regulatory expectations

Robust private key security and access controls

Segregation and redundancy to avoid single points of failure

Tested recovery and continuity capabilities

Audit-ready recordkeeping and evidence production

Cross-jurisdiction regulatory themes

Across jurisdictions, regulators converge around four core pillars:

Private key governance
  • Clear ownership, strong access controls, and reduced online key exposure.
Operational resilience
  • Documented recovery plans, regularly tested processes, and continuity readiness.
Governance & accountability
  • Defined responsibilities, approval steps, and ongoing oversight.
Audit logs & documented procedures
  • Audit logs, documented processes, and end-to-end traceability for recovery events.
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Private key governance
  • Clear ownership, strong access controls, and reduced online key exposure.
Operational resilience
  • Documented recovery plans, regularly tested processes, and continuity readiness.
Governance & accountability
  • Defined responsibilities, approval steps, and ongoing oversight.
Audit logs & documented procedures
  • Audit logs, documented processes, and end-to-end traceability for recovery events.
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About this regulatory review

The CoinCover Digital Asset Recovery Regulatory Review is a practical overview of what regulators across key jurisdictions expect firms to demonstrate—strong private key controls, segregation and redundancy, tested recovery and continuity processes, and audit-ready evidence. 
This independent regulatory research was undertaken by LHI Consulting, on behalf of CoinCover. Please note that CoinCover does not provide legal or regulatory compliance services. Responsibility for regulatory compliance remains with the regulated entity. CoinCover products support firms in implementing technical and operational controls that may assist in meeting regulatory expectations.

CoinCover Recover for Institutions

Keep your keys secure, behind rock-solid hot and cold protection

Regulatory review summary

Jurisdiction Regulations  Themes How CoinCover Assists
Australia
ASIC INFO 225, RG 133, Custody Guidance (Part E), Report 705 Key control as custody trigger; hot storage minimisation; private key safeguards; operational resilience & recordkeeping

CoinCover Recover: Supports secure recovery flows and assists with verification checks.

CoinCover Recover for Institutions: Supports reduced online key exposure.

Both: Supports clear recovery records.

Canada CSA Staff Notices (e.g., 21-329, 21-332) and PRU expectations; FINTRAC MSB regime Custody safeguards; resiliency & security controls; assurance expectations; AML/CTF recordkeeping

CoinCover Recover: Captures structured recovery case records.

CoinCover Recover for Institutions: Establishes controlled recovery steps.

European Union MiCA (Articles 62, 70); DORA (Chapter II: Articles 6, 11)

Safekeeping & private key protection; ICT risk management; BCP/DR; incident readiness; third-party risk

CoinCover Recover: Supports recoverability and continuity.

CoinCover Recover for Institutions: Supports firms with the generation of evidence for testing and incidents.

Hong Kong

SFC VATP Guidelines (2022) (incl. 98/2 requirement; 10.6(c) 10.8(a); related SFC/HKMA security governance guidance

98/2 cold storage expectation; key safeguards; segregation & redundancy; single-point-of-failure avoidance

CoinCover Recover: Enables secure recovery flows.

CoinCover Recover for Institutions: Strengthens recoverability for offline storage setups.

Singapore

Payment Services Act; MAS TRM Guidelines (s.8–10); FSMA reporting/returns

Technology risk governance; DR/BCP; supervisory readiness; record production

CoinCover Recover: Standardises recovery processes.

CoinCover Recover for Institutions: Aligns recovery planning with continuity needs.

Both: Produces records when requested.

United Arab Emirates VARA Regulations 2023 (Rule 2.4 and 2.6); ADGM FSRA 2022 Guidance (Section 9.3.3 and 9.3.7) Operational resilience; segregation & geographic redundancy; scenario-based recovery; RTO/RPO alignment

CoinCover Recover: Standardises recovery processes.

CoinCover Recover for Institutions: Creates separated, resilient recovery arrangements.

United Kingdom FCA SYSC 4.1 and 13; Principles for Businesses (Principle 10 and 12) Systems & controls; continuity; client asset protection; governance

CoinCover Recover: Reduces disruption from access-loss events.

CoinCover Recover for Institutions: Reinforces strong recovery controls.

Both: Maintains records for oversight.

United States SEC custody expectations; SEC Item 1.05; Reg SCI; cybersecurity disclosure expectations Key safeguarding policies; resiliency & integrity; incident documentation readiness; governance controls

CoinCover Recover for Institutions: Establishes controlled recovery procedures.

Both: Generates time-stamped recovery records.

 

 

How often do we need to show evidence to regulators?

Requirements vary by jurisdiction, but annual testing and ongoing governance are common themes. CoinCover supports this with the ability to run annual recovery simulations, generate certification, and provide quarterly review evidence you can use across multiple regulatory jurisdictions.

Designed to support global regulatory requirements.

We'll help support your firms' alignment with regulatory expectations including:

 

EU MiCA and DORA timelines and resilience expectations

US SEC-related safeguarding and disclosure expectations

Other jurisdictions with similar expectations on custody, resilience, and consumer protection

EU MiCA and DORA timelines and resilience expectations

US SEC-related safeguarding and disclosure expectations

Other jurisdictions with similar expectations on custody, resilience, and consumer protection

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