Bitcoin Treasury Readiness
Checklist
14 essential governance, technical, and compliance items every CFO should verify before allocating to Bitcoin.
Most treasury teams evaluating Bitcoin focus on the investment thesis but miss critical operational requirements. This checklist covers the governance, technical, and compliance groundwork you must complete before making an allocation decision — regardless of allocation size.
Check each item as completed. Share with your board, CFO, or risk committee. Reference during auditor discussions. A completed checklist signals institutional-grade readiness.
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✓Board approval process documentedInvestment policy statement amended to permit digital asset allocation. Board resolution on file with specific vote count and date.
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✓Investment policy statement (IPS) updatedIPS explicitly addresses digital assets: permitted allocation range (e.g., 1-5% of reserves), rebalancing triggers, and risk thresholds.
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✓Risk committee or oversight body assignedNamed committee responsible for ongoing oversight of digital asset position. Meeting cadence defined (minimum quarterly).
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✓Fiduciary duty analysis completedLegal review confirming Bitcoin allocation aligns with fiduciary obligations to shareholders. Memo signed by external counsel.
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✓Allocation size and entry strategy definedTarget allocation % determined. Dollar-cost averaging schedule vs. lump sum decision documented. Rebalancing policy written.
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✓Institutional custodian selected and due diligence completeCustodian evaluated against: regulatory status (BitLicense/trust charter), insurance coverage ($xM per wallet), SOC 2 Type II certification, and track record.
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✓Key management protocol designedMulti-signature setup configured (e.g., 3-of-5). Key holders identified. Key generation ceremony documented. Hardware wallets procured and tested.
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✓Insurance coverage confirmedCrime/cyber policy reviewed for digital asset coverage. Custodian insurance + supplemental policy if needed. Coverage amount documented relative to holding size.
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✓Disaster recovery and backup custodian planRecovery procedures tested (seed phrase recovery, wallet restoration). Backup custodian identified. Succession plan for key holder departure documented.
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✓Transaction authorization controls establishedDual control for transactions above threshold. Approval workflow documented (who can authorize, minimum approvers). Withdrawal whitelist configured.
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✓Accounting treatment determined (ASC 350 / IFRS)Classification confirmed (indefinite-lived intangible asset under ASC 350 pre-2024; fair value option available under ASU 2023-08). Journal entry templates prepared. CFO sign-off.
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✓Tax reporting strategy confirmed with counselCost basis method selected (FIFO, LIFO, specific identification). Capital gains/loss tracking system identified. State and international tax implications reviewed.
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✓Auditor briefing completedExternal auditors informed of planned Bitcoin position. Audit procedures for existence verification confirmed (blockchain confirmation, custodian attestation). Audit fees adjusted.
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✓Public disclosure and stakeholder communications planBoard deck prepared explaining strategy, risk management, and governance. Investor Q&A drafted. Press release template ready (for public companies). Volatility response script approved.
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