The Handbook
Endnotes
almeida, j , and t c gonçalves "a systematic literature review of volatility and risk management on cryptocurrency investment " mdpi risks journal , 2022 https //www mdpi com/2227 9091/10/5/107 alternative investment management association (aima) "aima publishes fund manager code of conduct (fmcc) implementation guide " october 2018 https //www aima org/article/aima publishes fund manager code of conduct fmcc implementation guide html alternative investment management association (aima) "aima publishes new guide on digital asset trading " may 10, 2023 https //www aima org/article/press release aima publishes new guide on digital asset trading html alternative investment management association (aima) "aima updates its guide to sound practices for investor relations " november 25, 2024 https //www aima org/article/aima updates its guide to sound practices for investor relations html alternative investment management association (aima) "aima's policy principles " https //www aima org/regulation/aima s policy principles html alternative investment management association (aima) "digital assets & anti money laundering " october 5, 2022 https //www aima org/event/digital assets—anti money laundering html alternative investment management association (aima) "guide to sound practices for the valuation of investments " 2018 https //www sec gov/comments/s7 07 20/s70720 7464497 221255 pdf alternative investment management association (aima) "guides to sound practices " https //www aima org/sound practices/guides to sound practices html alternative investment management association (aima) "integrating your digital assets technology stack with the traditional asset manager operating model " september 23, 2024 https //www aima org/journal/aima journal—edition 139/article/integrating your digital assets technology stack with the traditional asset manager operating model html alternative investment management association (aima) "investor relations an aima guide to sound practices " https //www aima org/compass/practical guides/marketing investor relations/investor relations html alternative investment management association (aima) "digital asset trading an aima industry guide " may 2023 https //www aima org/compass/insights/digital assets/digital asset trading html arxiv "quantifying crypto portfolio risk a simulation based framework " july 2025 https //arxiv org/html/2507 08915v1 bitgo "crypto custody for hedge funds security and compliance " july 10, 2025 https //www bitgo com/resources/blog/crypto custody for hedge funds security compliance and growth strategies/ bitgo "crypto disaster recovery safeguarding your digital assets " july 24, 2025 https //www bitgo com/resources/blog/crypto disaster recovery/ california law review "applying the sec custody rule to cryptocurrency hedge fund managers " https //www californialawreview\ org/print/applying the sec custody rule to cryptocurrency hedge fund managers cfa institute "asset manager code of professional conduct " 2019 https //www cfainstitute org/en/ethics standards/codes/asset manager code cfa institute "elements of an investment policy statement for institutional investors " https //rpc cfainstitute org/sites/default/files/ /media/documents/article/position paper/investment policy statement institutional investors pdf cfa institute "global investment performance standards (gips) " 2020 ed https //www cfainstitute org/en/ethics standards/codes/gips standards cfa institute "global investment performance standards (gips) handbook " 2nd ed , 2007 https //www gipsstandards org/wp content/uploads/2021/03/gips handbook 2nd edition pdf cfa institute "investment management governance " https //rpc cfainstitute org/policy/positions/investment management governance cfa institute "portfolio management an overview " october 3, 2025 https //www cfainstitute org/insights/professional learning/refresher readings/2025/portfolio management overview cfa institute "standard vi(a) avoid or disclose conflicts " updated january 2024 https //www cfainstitute org/standards/professionals/code ethics standards/standards of practice vi a collas crill "crypto asset investment structures a primer " january 30, 2025 https //www collascrill com/articles/crypto asset investment structures a primer/ cornell law school "17 cfr § 275 206(4) 7 compliance procedures and practices " https //www law\ cornell edu/cfr/text/17/275 206(4) 7 cyber risk institute (cri) "the cri profile a financial sector use case for the nist csf " 2024 https //cyberriskinstitute org/wp content/uploads/2024/05/the cri profile a financial sector use case for the nist csf 2023 pdf deloitte "2025 investment management regulatory outlook " https //www deloitte com/us/en/services/consulting/articles/investment management regulatory outlook html deloitte "lessons in digital asset risk management " 2025 https //www deloitte com/us/en/services/audit assurance/articles/blockchain digital assets risk management html dla piper "cftc updates guidance on compliance programs and enforcement " https //www dlapiper com/en us/insights/publications/2020/09/cftc updates guidance on compliance programs and enforcement european securities and markets authority "alternative investment fund managers directive (aifmd) " directive 2011/61/eu, june 8, 2011 https //eur lex europa eu/legal content/en/txt/?uri=celex 32011l0061 european securities and markets authority "markets in crypto assets regulation (mica) " regulation (eu) 2023/1114, june 9, 2023 https //eur lex europa eu/legal content/en/txt/?uri=celex 32023r1114 european systemic risk board "systemic liquidity risk a monitoring framework " https //www esrb europa eu/pub/pdf/reports/esrb report202501 systemicliquidityrisk 90f2044791 en pdf ey parthenon "2025 institutional investor digital assets survey growing enthusiasm propels digital assets into the mainstream " march 18, 2025 https //www ey com/content/dam/ey unified site/ey com/en us/insights/financial services/documents/ey growing enthusiasm propels digital assets into the mainstream pdf fabozzi, frank j hedge funds structure, strategies, and performance hoboken, nj john wiley & sons, 2004 federal reserve bank of new york "the financial stability implications of digital assets " economic policy review , november 2024 https //www newyorkfed org/research/staff reports/sr1034 financial action task force "guidance for a risk based approach to virtual assets and virtual asset service providers " updated october 2021 https //www fatf gafi org/content/dam/fatf gafi/guidance/updated guidance va vasp pdf financial action task force "international standards on combating money laundering and the financing of terrorism & proliferation " updated october 2023 https //www fatf gafi org/content/dam/fatf gafi/recommendations/fatf%20recommendations%202012 pdf financial conduct authority (uk) "fca handbook conduct of business sourcebook (cobs) " https //www handbook fca org uk/handbook/cobs/ financial conduct authority (uk) "guidance on cryptoassets " policy statement ps19/22, july 31, 2019 https //www fca org uk/publication/policy/ps19 22 pdf financial crimes enforcement network "application of fincen's regulations to certain business models involving convertible virtual currencies " fin 2019 g001, may 9, 2019 https //www fincen gov/sites/default/files/2019 05/fincen%20guidance%20cvc%20final%20508 pdf financial crime academy "the power of compliance aml regulations for cryptocurrency unleashed " https //financialcrimeacademy org/aml regulations for cryptocurrency/ financial professionals organization "10 treasury policies every company should have " april 14, 2025 https //www financialprofessionals org/training resources/resources/articles/details/10 treasury policies every company should have financial stability board "assessment of risks to financial stability from crypto assets " february 16, 2022 https //www fsb org/wp content/uploads/p160222 pdf financial stability board "regulation, supervision and oversight of crypto asset activities and markets " july 17, 2023 https //www fsb org/wp content/uploads/p170723 2 pdf fintech global "how to prepare for the 2025 form adv update key compliance tips " https //fintech global/2025/03/12/how to prepare for the 2025 form adv update key compliance tips/ fireblocks "addressing counterparty risk with fireblocks off exchange " https //www fireblocks com/blog/addressing counterparty risk and unlocking new opportunities with fireblocks off exchange/ fireblocks "digital asset custody and transaction processing leading practices using fireblocks' mpc solution " june 28, 2025 https //www fireblocks com/report/digital asset custody and transaction processing leading practices using fireblocks mpc solution/ fireblocks "disaster recovery services a new standard for digital asset security " march 21, 2025 https //www fireblocks com/blog/disaster recovery services new standard digital asset security/ fireblocks "mitigating digital asset and crypto counterparty risk " https //www fireblocks com/blog/mitigating digital asset and crypto counterparty risk/ fireblocks "what is digital asset custody?" https //www fireblocks com/digital asset custody/ fordham law review "protecting investors from hedge fund managers' conflicts of interest " https //ir lawnet fordham edu/flr/vol77/iss6/9/ fund associates "sound practices for hedge fund managers " https //www fundassociates com/sound practices/ galaxy digital "a risk rating framework for defi and crypto investors " 2025 https //www galaxy com/insights/research/risk rating defi crypto global association of risk professionals (garp) "digital asset risk management var meets cryptocurrencies " october 18, 2024 https //www garp org/risk intelligence/market/digital asset risk 241018 global reporting initiative "gri standards " 2021 https //www globalreporting org/standards/ government finance officers association (gfoa) "investment policy " https //www gfoa org/materials/investment policy government finance officers association (gfoa) "treasury and investment management best practices " https //www gfoa org/best practices/treasury operations greenberg traurig "federal banking regulators issue guidance on risk management for crypto asset safekeeping activities " 2025 https //www gtlaw\ com/en/insights/2025/7/federal banking regulators issue guidance on risk management for crypto asset safekeeping activities guizot, armelle the hedge fund compliance and risk management guide hoboken, nj john wiley & sons, 2006 harvard law school forum on corporate governance "hedge fund governance " https //corpgov law\ harvard edu/2013/04/15/hedge fund governance/ hedge fund law report "how can hedge fund managers structure managed accounts " https //www pelawreport com/2678721/how can hedge fund managers structure managed accounts to remain outside the purview of the amended custody rules surprise examination requirement thtml hedge fund law report "key person provision drafting and legal requirements " 2025 https //www hflawreport com/key person provision drafting legal requirements/ hunton andrews kurth "sec and cftc propose digital asset reporting on form pf " https //www hunton com/blockchain legal resource/sec and cftc propose digital asset reporting on form pf international monetary fund "global financial stability report digital money across borders " october 2023 https //www imf org/en/publications/gfsr/issues/2023/10/10/global financial stability report october 2023 international organization for standardization "iso/iec 27001 2013 information security management systems " 2013 https //www iso org/standard/54534 html international organization for standardization "iso/iec 27002 2022 information security controls " 2022 https //www iso org/standard/75652 html international organization of securities commissions "policy recommendations for crypto and digital asset markets " may 2023 https //www iosco org/library/pubdocs/pdf/ioscopd734 pdf international organization of securities commissions "principles for financial market infrastructures " april 2012 https //www iosco org/library/pubdocs/pdf/ioscopd377 pdf irs "form 1023 purpose of conflict of interest policy " https //www irs gov/charities non profits/form 1023 purpose of conflict of interest policy journal of community development research "blockchain based risk management framework for digital asset exchanges bridging coso erm with emerging technologies " 2025 https //so18 tci thaijo org/index php/jcdr hs/article/view/807 keiter cpa "2025 digital asset reporting | form 1099 da " https //keitercpa com/blog/new digital asset tax reporting regulations 2025/ kim, c y , and k lee "risk management to cryptocurrency exchange and investors guidelines to prevent potential threats " ieee conference on platform technology and service, 2018 kitces "guide to documenting annual compliance review sec amendment " https //www kitces com/blog/annual compliance review sec investment adviser written requirements rule 20647/ kleinberg kaplan "preserving a hedge fund's business and legacy the keys to a robust succession plan " https //www kkwc com/wp content/uploads/2017/08/preserving a hedge fund%e2%80%99s business and legacy the keys to a robust succession plan hedge fund lcd pdf managed funds association sound practices for hedge fund managers 2009 ed washington, d c mfa, 2009 managed funds association "sound practices for hedge fund managers " https //www cftc gov/sites/default/files/idc/groups/public/@swaps/documents/file/soundpractices pdf merkle science "counterparty risk in crypto understanding the potential threats " https //www merklescience com/counterparty risk in crypto understanding the potential threats merkle science "what is counterparty analysis " https //www merklescience com/what is counterparty analysis and how does it apply to crypto companies mishcon de reya "crypto and the fatf 'travel rule' " https //www mishcon com/news/crypto and the fatf travel rule mondrian alpha "the evolution of quantitative risk management in hedge funds " https //www mondrian alpha com/articles/investment/quantitative risk management morris, peter j t all about hedge funds the easy way to get started new york mcgraw hill, 2004 national institute of standards and technology "cybersecurity framework version 1 1 " april 16, 2018 https //www nist gov/cyberframework national institute of standards and technology (nist) "the nist cybersecurity framework (csf) 2 0 " february 26, 2024 https //nvlpubs nist gov/nistpubs/cswp/nist cswp 29 pdf nber "hedge fund leverage " https //www nber org/system/files/working papers/w16801/w16801 pdf nyu compliance & enforcement "proposed sec custody rules for crypto assets " https //wp nyu edu/compliance enforcement/2023/03/16/proposed sec custody rules for crypto assets/ office of the comptroller of the currency "interpretive letter 1170 on crypto asset custody services " 2020 https //www occ gov/topics/charters and licensing/interpretations and actions/2020/int1170 pdf office of the comptroller of the currency "occ clarifies bank authority to engage in crypto asset custody and execution services " may 7, 2025 https //www occ gov/news issuances/news releases/2025/nr occ 2025 42 html office of the comptroller of the currency, federal reserve, and fdic "agencies issue joint statement on risk management considerations for crypto asset safekeeping " july 14, 2025 https //www occ gov/news issuances/news releases/2025/nr ia 2025 68 html office of the comptroller of the currency, federal reserve, and fdic "crypto asset safekeeping by banking organizations " july 14, 2025 https //www occ gov/news issuances/news releases/2025/nr ia 2025 68a pdf paul, weiss "private funds regulatory compliance calendar 2025 " https //www paulweiss com/media/cgskoxtn/private funds regulatory compliance calendar 2025 pdf plansponsor "managing counterparty risk more important for 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com/news/setting the standards blog series part 1 the foundation of fund administration for digital assets richey may & co "unique valuation considerations for crypto asset managers " 2024 https //richeymay com/resource/whitepapers/unique valuation considerations for crypto asset managers/ shadab, houman b "hedge fund governance " stanford journal of law, business & finance 19, no 1 (fall 2013) 141 202 https //digitalcommons nyls edu/fac articles chapters/1037 sidley "crypto focused private fund adviser settles with u s sec for custody rule and other violations " https //www sidley com/en/insights/newsupdates/2024/09/crypto focused private fund adviser settles with us sec for custody rule and other violations soni, u , and r g preece "valuation of cryptoassets a guide for investment professionals " cfa institute research and policy center, 2023 https //rpc cfainstitute org/research/reports/2023/valuation cryptoassets standards board for alternative investments (sbai) "alternative investment standards " 2020 https //www sbai org/standards/ standards board for alternative investments (sbai) "culture and diversity principles " 2024 https //www sbai org/asset/a13a3bfa 2771 4f42 ad55b07e9694914e/ standards board for alternative investments (sbai) "cyber security (small & mid size firms) " https //www sbai org/static/bdcd6b3b bb90 49b7 b5835c2d4de4d3e9/cyber security small & mid size firms pdf standards board for alternative investments (sbai) "governance " https //www sbai org/toolbox resources/governance html standards board for alternative investments (sbai) "investment dd and the standards " https //www sbai org/resource/investment dd and the standards html standards board for alternative investments (sbai) "operational due diligence of digital assets " november 2021 https //www sbai org/static/5e928706 402a 43da a036b82c6a7fd8c6/operational due diligence on digital assets pdf f standards board for alternative investments (sbai) "responsible investment policy framework " 2024 https //www sbai org/static/dfcb3593 d5fb 4b9e b761fd8bca67968b/responsible investment policy framework pdf standards board for alternative investments (sbai) "responsible investment toolbox resources " 2024 https //www sbai org/toolbox resources/responsible investment html standards board for alternative investments (sbai) "standardised board agenda " https //www sbai org/static/373e2aa6 b543 4041 bc3bc83f72816741/standardised board agenda pdf state street "digital digest july 2025 digital asset custody " july 2025 https //www statestreet com/cn/en/insights/digital digest july 2025 digital asset custody sustainability accounting standards board "sasb standards for asset management & custody activities " 2023 https //www sasb org/standards/materiality finder/ talos "bridging the liquidity gap how digital asset infrastructure is rising to meet institutional demands " september 29, 2025 https //www talos com/insights/bridging the liquidity gap how digital asset infrastructure is rising to meet institutional demands talos "nasdaq trade talks the pace of institutional adoption of digital assets " https //www talos com/insights/the pace of institutional adoption of digital assets the hedge fund journal "a seven step guide to effective business continuity planning " https //thehedgefundjournal com/a seven step guide to effective business continuity planning/ the hedge fund journal "business continuity for hedge fund managers " https //thehedgefundjournal com/business continuity for hedge fund managers/ the hedge fund journal "counterparty exposure risk " https //thehedgefundjournal com/counterparty exposure risk/ the hedge fund journal "it considerations for disaster recovery " https //thehedgefundjournal com/it considerations for disaster recovery/ the hedge fund journal "managing potential conflicts of interest " https //thehedgefundjournal com/managing potential conflicts of interest/ the hedge fund journal "risk practices in hedge funds " https //thehedgefundjournal com/risk practices in hedge funds/ troutman pepper "digital asset regulation and the clarity act of 2025 " https //www troutman com/insights/digital asset regulation and the clarity act of 2025 html trustpair "wire transfer fraud definition, strategies and recovery " june 30, 2025 https //trustpair com/blog/wire transfer fraud prevention best practices and recovery/ u s congress "genius act federal regulatory framework for stablecoins " signed into law july 18, 2025 https //www congress gov/committee report/119th congress/house report/94/1 u s department of the treasury "action plan for addressing illicit financing risks of digital assets " september 2022 https //home treasury gov/system/files/136/digital asset action plan pdf u s department of the treasury "financial management standards " august 21, 2025 https //tfx treasury gov/fm standards u s securities and exchange commission "compliance programs of investment companies and investment advisers " https //www sec gov/rules regulations/2003/12/compliance programs investment companies investment advisers u s securities and exchange commission "crypto asset exchange traded products disclosure requirements " 2025 https //www sec gov/newsroom/speeches statements/cf crypto asset exchange traded products 070125 u s securities and exchange commission "crypto asset custody by investment advisers after the sec's proposed safeguarding rule " https //www sec gov/about/crypto task force/crypto task force written input/ctf written rscr walker 03222023 u s securities and exchange commission "custody of funds or securities of clients by investment advisers " 17 cfr § 275 206(4) 2 https //www sec gov/rules/final/ia 2176 htm u s securities and exchange commission "digital asset securities " staff accounting bulletin no 121, march 31, 2022 https //www sec gov/oca/staff accounting bulletin 121 u s securities and exchange commission "framework for 'investment contract' analysis of digital assets " april 3, 2019 https //www sec gov/corpfin/framework investment contract analysis digital assets u s securities and exchange commission "interpretive matters concerning independent directors of investment companies " https //www sec gov/rules regulations/1999/10/interpretive matters concerning independent directors investment companies u s securities and exchange commission "investment advisers act of 1940 section 206(4) / rule 206(4) 3 " https //www sec gov/divisions/investment/noaction/2019/wells fargo securities 032119 2064 u s securities and exchange commission "office hours with gary gensler what is a qualified custodian " https //www sec gov/newsroom/speeches statements/office hours gary gensler qualified custodian u s securities and exchange commission "role of independent directors of investment companies " https //www sec gov/rules regulations/2001/01/role independent directors investment companies unchained "what is counterparty risk in crypto?" https //unchainedcrypto 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