Deciphr Academy
Track 5 · Module 24 · Lesson 3 of 7 · 8 min read

Where can a crypto company hold its treasury, and what can go wrong in each place?

Short answer

Every place depends on someone: a bank, a stablecoin issuer, an exchange or custodian, or the signers and code behind a multisig.1,2,3 Some DAOs publish limits on how much can sit in any one place, and the March 2023 USDC depeg showed how one bank's failure can reach a stablecoin.4,5

Bankdepositsdepends onthe bankinsured to $250,000Stablecoina dollar tokendepends onthe issuerand its reservesExchangeor custodiandepends onits termsand staying solventMultisigyour own Safedepends onthe signersand the codeEvery place depends on someone. Write the list down
Fig. 3. Four places to hold a treasury, and who each one depends on.

Everyone you depend on

Wherever money sits, someone else is involved. The Bank for International Settlements (BIS) defines custody risk as the risk of losing assets held in custody because the custodian goes bust, is careless, commits fraud, runs things badly or keeps poor records.2

Concentration is the other half of the problem: holding a large share of the treasury in one asset, or with one bank, platform or protocol.6,4 If that one place fails, a large share of the money is stuck at once.5

Banks

Bank deposits in the US are insured by the FDIC, but only up to $250,000 per depositor, per insured bank, for each account ownership category.1 Deposit insurance does not cover crypto assets, and it does not cover the failure of a firm that is not an FDIC-insured bank.1 Module 23 explains company deposits and the 2023 bank failures in detail.1

Stablecoins

A stablecoin is only as good as the issuer and the reserves behind it, as Module 22 explains. In March 2023, Circle said it could not withdraw $3.3 billion of USDC's reserves, about 8% of the total, from the failed Silicon Valley Bank (SVB).5 A Federal Reserve staff note says USDC fell to 86 cents at its lowest.5

So a company that banked only at SVB and held only USDC would have been exposed to the same failure twice. On Sunday 12 March, the US Treasury, the Federal Reserve and the FDIC announced a backstop, and USDC fully recovered once Circle began processing redemptions on Monday 13 March.5

Exchanges and lending platforms

When you leave crypto with a platform, what you own depends on its terms. Celsius, a crypto platform, filed for bankruptcy in July 2022.3 In January 2023, the US bankruptcy court ruled that, under Celsius's terms of use and subject to defences it left open, crypto deposited in its "Earn" accounts had become Celsius's property, and so belonged to the bankruptcy estate.3 The terms had warned that, if Celsius went bankrupt, those assets "may not be recoverable".3

Those Earn accounts numbered about 600,000 and held crypto worth about $4.2 billion in July 2022.3 The ruling was about Celsius's own terms. Other platforms' terms differ, which is why the terms are worth reading before the money goes in.3,2

Custodians and multisigs

A custodian is a firm that holds assets for others. Some treasuries spread their holdings across several. In June 2026, the Optimism Foundation said the Optimism Collective held about 19,300 ETH, split across several institutional custodians, a liquid staking position and one unstaked account.7 It proposed cutting to fewer custodians, to reduce overhead and simplify reporting.7 Optimism governance approved the plan in July 2026. The approved plan also lets the Foundation use covered calls and collars, which are options deals, on up to two-thirds of the ETH. The proposal says covered calls earn extra income but cap the gain if ETH rises.8,7 Fewer providers can mean less work, but more depends on each one.7,2

Many DAOs hold funds in multisig wallets, which need several signers to approve each payment, as Module 9 explains. For one ETH sale, ENS set up a separate Safe needing 3 signatures, from signers representing different parties, to keep that money apart from its other wallets.9

Tokenised Treasury funds

Some DAOs now hold tokenised funds that invest in US Treasury bills, which Module 16 covers. In mid-2024, Arbitrum DAO put $30 million into six products, mainly tokenised Treasury bill and money market funds, through its Stable Treasury Endowment Program (STEP).10 By August 2025, the Arbitrum Foundation said it had converted another 35 million ARB and placed the proceeds in three more products, and it published the addresses that held them.11

Limits on any one place

ENS DAO's 2026 investment policy is a public example of written limits. These are one DAO's choices, not rules for everyone:4

  • No more than 30% of the endowment in any single protocol.4
  • No ETH placed with or through centralised exchanges.4
  • Tokenised Treasury and money market funds capped at 5% of the endowment, from regulated issuers with published audits or attestations.4
  • Stablecoins not tied to the US dollar capped at 5% of the stablecoin holdings.4
General education, not legal advice

This lesson is general education, not legal advice. Rules on deposit insurance and bankruptcy differ between countries and change over time, and the Celsius ruling turned on Celsius's own terms of use.1,3

Our viewThere is no risk-free place to keep a treasury. There are only places where you know who you depend on and places where you don't. Writing that list down is most of the work.
Sources
  1. Understanding Deposit Insurance. Federal Deposit Insurance Corporation (FDIC), read 24 October 2026.
  2. Tokenisation in the context of money and other assets: concepts and implications for central banks. Bank for International Settlements and Committee on Payments and Market Infrastructures, report to the G20, October 2024.
  3. In re Celsius Network LLC: Memorandum Opinion and Order Regarding Ownership of Earn Account Assets. US Bankruptcy Court for the Southern District of New York, Case No. 22-10964 (MG), 4 January 2023.
  4. [EP 6.46] [Social] 2026 Endowment Investment Policy Update. ENS DAO governance documents (posted on the ENS forum on 8 May 2026; status: passed, in a Snapshot vote held from 24 to 29 June 2026), June 2026.
  5. In the Shadow of Bank Runs: Lessons from the Silicon Valley Bank Failure and Its Impact on Stablecoins (FEDS Notes). Board of Governors of the Federal Reserve System (Chuan Du, Ria Sonawane and Cy Watsky), 17 December 2025.
  6. How are you DAOing? The state of DAO treasuries (BRL Research Note #3). Blockchain Research Lab, 16 October 2023.
  7. Sequencer ETH Management: 12-Month Renewal and Treasury Optimization (proposal). Optimism Foundation, Optimism governance forum (proposal; approved in an on-chain vote that ran from 9 to 15 July 2026, and executed on 21 July 2026), 25 June 2026.
  8. Sequencer ETH Management: 12-Month Renewal and Treasury Optimization (on-chain vote). Optimism governance (Agora voting site), read 24 October 2026, vote 9 to 15 July 2026; executed 21 July 2026.
  9. [EP 6.1] [Executable] Convert 6,000 ETH to USDC for DAO Operating Expenses (proposal and execution updates). ENS DAO governance forum (proposal posted by karpatkey, later KPK), 24 January 2025, with updates to 13 May 2025.
  10. Non-Constitutional: Stable Treasury Endowment Program 2.0. Arbitrum DAO governance forum (proposal; on-chain vote from 28 January 2025), first posted 17 September 2024.
  11. STEP 2 Committee Preferred Allocations (post #35). Arbitrum Foundation, Arbitrum DAO governance forum, 4 August 2025.

General education built from the publicly available sources listed above. Not financial, legal, tax or investment advice. Naming a company, project or regulator is not an endorsement either way. Last checked 2026-10-24. Terms and disclaimer.