Cryptocurrency as a Treasury Asset: Are Your Controls and Policies in Place?

As digital assets like Bitcoin continue to gain mainstream traction, companies such as Block Inc. (formerly Square), MicroStrategy, and Tesla have drawn attention by adding crypto to their balance sheets.

While motivations such as asset diversification, innovation, and long-term value appreciation may seem compelling, each decision to invest in cryptocurrency comes with a complex web of operational, financial, and accounting challenges that companies must be prepared to navigate.

Before a company can hold cryptocurrency as a treasury asset or use it for payments, it must first establish the necessary internal infrastructure to safeguard the asset, accurately account for it in its books and records, and maximize its value to the organization. This includes everything from exchange selection to implementing appropriate and relevant internal controls.

Companies must be prepared to ask themselves not just “Can we buy cryptocurrency?” but more importantly, “Are we ready to buy cryptocurrency?”.

Without properly preparing your teams for the purchase of this new asset class, companies run the risk of exposure to pitfalls such as the lack of segregation of duties, poor access controls, incorrect accounting, and having no formalized audit trail. In this article, we will discuss some crucial questions that companies should be able to answer before leaping into purchasing cryptocurrency.

Internal Infrastructure Before Initial Investment

To determine whether a company is truly ready to purchase and manage cryptocurrency, it’s essential to be able to answer these pointed questions to assess their operational readiness:

1. Where and How is the Company Buying?

• Exchange, OTC, or Broker? Decide how they will gain exposure. Each has different onboarding, fees, and custody models.
• Banking Considerations: Will their current bank support crypto transactions? If not, they may need a new banking partner.

2. Who Has Access and Approval?

• Access Management: Who holds the keys? Who can log in to the exchange or your custodian? Who approves of purchases and sales?
• Segregation of Duties: Ensure no single person can initiate and approve transactions. Use multi-signature wallets and role-based access.

3. How Will Companies Account for It?

• Financial Reporting: For assets within the scope of ASU 2023-08, crypto assets are held at fair value with unrealized gains and losses flowing through the income statement[1].
• With that in mind, does the Company have the internal expertise to account for this new intangible asset appropriately?
• SOX Compliance: Document controls, test them regularly, and ensure auditability. Crypto holdings must be reconciled and reported in the same manner as any other asset. This means retaining documentation in a secure space for each step in the process, including purchase, storage, reporting, and reconciliations.

4. Can the Company Pay Vendors or Employees?

• Payroll Engines: Most traditional payroll systems don’t support crypto. Companies with these digital assets may need a third-party provider or a workaround.
• Tax and Legal: Paying in crypto triggers taxable events. Ensure the company has internally or externally sourced knowledge to ensure compliance with IRS and labor laws.

Ultimately, crypto isn’t just a treasury asset; it introduces an entirely new business process that companies must proactively plan for by taking the following steps:

• Develop a Crypto Treasury Policy: Define purpose, limits, and procedures, and continually ensure adherence to the policy.
• Implemented Controls: Think like a regulator. Build approvals, access logs, and reconciliation processes.
• Educate Stakeholders: From finance to legal to IT, everyone needs to understand the risks and responsibilities.

How Centri Can Help

Navigating the complexities of a crypto treasury strategy demands both expertise and precise execution. At Centri, we help companies assess their current readiness and implement adequate internal controls. From understanding tax and legal implications to evaluating third-party solutions and building compliant, scalable processes, our team partners with you to create a framework that supports growth while minimizing risk. Contact us to help you take the next step in confidently managing your digital asset strategy.

Sources:

1. CoinGecko. (n.d.). Public companies with Bitcoin on their balance sheet. Retrieved June 25, 2025, from https://www.coingecko.com/en/public-companies-bitcoin
2. Deloitte. (2021). Corporations investing in crypto: Considerations regarding risks, controls, accounting, and tax. Retrieved from https://www2.deloitte.com/content/dam/Deloitte/us/Documents/audit/us-corporates-investing-in-crypto.pdf
3. Fidelity Digital Assets. (n.d.). Adding Bitcoin to the corporate treasury. Retrieved June 25, 2025, from https://www.fidelitydigitalassets.com/research-and-insights/adding-bitcoin-corporate-treasury#executive-summary
4. TheStreet. (2022). Companies holding Bitcoin on their balance sheets: A strategic investment. Retrieved from https://www.thestreet.com/crypto/innovation/

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[1] https://centriconsulting.com/news/insights/new-fasb-guidance-on-crypto-assets-what-you-need-to-know/

Centri’s Mike Andrusko Featured in Cryptonomix: Understanding ASU 2023-08 and Fair Valuing Your Digital Assets