January 22, 2026 · 1 min read · Harlyz Advisory
Control expectations are rising
Virtual asset regulators are converging on stricter requirements for custody, monitoring, and travel rule compliance. The firms that win approvals show clear ownership for each control and consistent evidence trails.
Three areas regulators examine first
Custody governance
Document wallet access control, key management, and reconciliation routines. Provide evidence of objective oversight and periodic audits.
Transaction monitoring
Monitoring programs should map to risk factors such as geography, asset type, and transaction velocity. Rules must be tuned and reviewed on a documented schedule.
Travel rule adherence
Show how originator and beneficiary data is captured, verified, and transmitted when required.
Closing insight
A credible VASP application demonstrates that controls are embedded in daily operations, not bolted on after launch.