7 April 2026
Client-asset segregation when wallets hold customer balances
How Hong Kong fintech firms can evidence that customer digital assets stay apart from proprietary holdings—beyond a policy paragraph.
Segregation for digital assets is not only a legal label on a wallet address. Supervisors and partners increasingly ask for evidence that signing authority, ledger coding, and bankruptcy-remoteness arrangements keep client balances identifiable and movable under stress.
Start with a living register of wallets and custodians that hold customer assets. For each entry, record the chain, custodian or self-custody model, who can initiate and approve transfers, and which ledger accounts map to those balances.
During control audits we sample transfers against dual-control rules and confirm that proprietary treasury wallets never share signing quorums with client pools. Breaks that surface in sampling are cheaper to fix than breaks that surface in an examination.