Preface

the digital fiduciary standards board (dfsb), an independent nonprofit, has created this handbook to bridge the gap between institutional allocators and digital asset managers the industry is at a pivotal point, with institutional investors recognizing digital assets as a legitimate asset class however, many disqualify crypto native managers not due to strategy issues but because they cannot demonstrate fiduciary grade management of client capital conversely, traditional asset managers have established fiduciary frameworks but lack the specific knowledge needed for digital asset custody, smart contract risks, and blockchain operations the challenge is primarily fiduciary in nature crypto native managers understand the markets and technology but struggle to prove they meet legal duties such as care, loyalty, and prudence required by institutional investors the handbook aims to address this by translating proven fiduciary standards into digital asset specific guidelines that are practical and applicable standards development these standards were developed through rigorous analysis of fiduciary requirements, regulatory expectations, and digital asset operational realities development incorporated consultation with institutional allocators to identify fiduciary requirements and disqualifiers in manager evaluation expertise from managers with experience in building institutional grade digital asset platforms review of sec, finra, cftc, and international regulations relevant to digital assets input from service providers such as administrators, auditors, custodians, and legal counsel each standard addresses real questions allocators ask during due diligence about whether managers can fulfill fiduciary obligations standards specify implementable frameworks that demonstrably satisfy fiduciary requirements while remaining practical for emerging managers scope and application we wrote this handbook to serve investment managers, allocators and institutional investors across jurisdictions while recognizing that specific regulatory requirements vary by region where regulatory mandates apply in certain jurisdictions, relevant considerations are identified however, these are standards and guidance, not legal requirements recommendations do not replace applicable legal or regulatory obligations, which are likely more detailed than the practices described firms remain solely responsible for ensuring compliance with all applicable laws, regulations, and contractual obligations professional legal, compliance, accounting, or other advice should be obtained where appropriate—these standards are not a substitute for such counsel intended audiences the handbook serves three primary audiences, each playing essential roles in bridging institutional capital and digital asset management digital asset investment managers seeking institutional capital if you manage, or intend to manage, capital for institutional allocators, these standards define fiduciary expectations for consideration firms managing exclusively retail capital may find standards overly prescriptive institutional allocators evaluating digital asset managers these standards provide due diligence frameworks, identify critical fiduciary areas, and establish baseline expectations for fiduciary grade management service providers supporting digital asset managers auditors, administrators, custodians, and legal counsel require understanding of fiduciary expectations to deliver appropriate services structure and navigation the handbook contains 17 standards covering every fiduciary area that institutional allocators assess during due diligence each standard follows a consistent structure providing operational frameworks, practitioner insights, allocator due diligence considerations, common pitfalls and remediation, and key controls and documentation requirements standards are intentionally detailed—institutional allocators reject vague descriptions and require specific frameworks with documented procedures implementation philosophy these standards provide a flexible, outcome based framework for fiduciary practices, scaled to firm size and complexity they avoid prescribing specific vendors or technologies, allowing firms to tailor their approaches while addressing digital asset realities implementation is iterative; firms can seek institutional capital without full compliance, as allocators evaluate fiduciary progress through controls and sophistication use these standards to demonstrate fiduciary capability, protect client assets, and meet legal duties required by institutional investors acknowledgments the dfsb thanks all stakeholders—allocators, managers, service providers, and the digital asset community—for their valuable contributions in developing practical standards that promote innovation and fiduciary responsibility standards will continue to evolve as markets develop, regulations change, and best practices emerge we welcome feedback from practitioners, allocators, and service providers dfsb may update this handbook periodically to reflect regulatory developments, market evolution, and emerging operational best practices managers should confirm they are using the current version available at dfsb org version number and publication date appear on the cover page the digital fiduciary standards board (dfsb) 201 clearwater drive | suite 1703 west palm beah, fl 33401 mailto\ info\@dfsb org