Custody & Settlement:
Hiring for Resilience in an Evolving Regulatory Landscape
8 min read
8 min read
Digital asset custody is entering a more mature phase.
As institutional participation grows and regulatory expectations become clearer, custody is increasingly being treated as critical financial infrastructure rather than a supporting function. In Switzerland, recent guidance from the Swiss Financial Market Supervisory Authority (FINMA) has reinforced that direction, with implications not only for how firms structure their custody arrangements, but also for the expertise they need internally.
For companies operating across blockchain, Web3, and fintech, this is becoming a talent question as much as a regulatory or technical one.
A Higher Standard for Crypto Custody
In January 2026, FINMA published Guidance 01/2026 on the custody of crypto-based assets, setting out its supervisory expectations and highlighting the particular risks associated with custody arrangements.
A central concern is the protection of client assets in the event of insolvency. FINMA emphasises the importance of custody structures that allow cryptoassets to be allocated to individual clients and separated from the custodian's bankruptcy estate.
The guidance also addresses the use of third-party custodians, including providers located outside Switzerland. Where an authorised institution delegates custody, responsibility does not simply disappear with the outsourcing arrangement. Firms must assess the legal and operational risks involved and ensure that appropriate protections remain in place.
The direction is clear: custody arrangements are being scrutinised not only for technical security, but for governance, operational resilience and legal certainty.
From Technical Function to Institutional Infrastructure
This matters because custody has evolved significantly alongside the digital asset market itself.
For many firms, the question is no longer simply how private keys are stored. Modern custody environments can involve multi-party computation, hardware security modules, policy engines, transaction monitoring, wallet infrastructure, third-party integrations and complex operational controls.
At the same time, those systems increasingly sit within regulated financial institutions or businesses serving institutional clients.
The result is a convergence between two historically distinct areas of expertise: digital asset infrastructure and regulated financial services.
That convergence is changing the profiles companies need to hire.
The Talent Requirement Is Becoming More Specialised
A strong custody team today may require expertise spanning wallet architecture, key management, cybersecurity, operational risk, AML controls, outsourcing governance and regulatory compliance.
Finding each of those capabilities individually is possible. Finding professionals who understand how they interact is considerably harder.
A technically strong infrastructure leader may understand MPC architecture, HSM environments and wallet security but have limited exposure to the governance requirements of a regulated financial institution.
Conversely, an experienced banking risk or compliance professional may understand outsourcing, operational controls and regulatory expectations without having worked directly with blockchain infrastructure.
Increasingly, firms need people who can operate across both environments.
This does not necessarily mean finding one individual who can do everything. It means building teams in which technical, operational and regulatory expertise can work together effectively — and identifying leaders capable of connecting those functions.
The Search Is Broader Than Crypto
This shift is also changing where relevant talent can be found.
Some of the strongest candidates will come directly from crypto-native custodians, exchanges, wallet providers and blockchain infrastructure companies. Others may come from banking, payments, cybersecurity, market infrastructure or institutional technology.
Job titles alone are therefore becoming a less reliable indicator of fit.
Relevant experience may sit across digital asset custody, information security, operational resilience, transaction monitoring, financial crime, payments infrastructure or regulated outsourcing.
For hiring teams, the challenge is increasingly to identify transferable expertise without losing sight of the technical specificity of digital assets.
Switzerland's Position Continues to Evolve
Switzerland remains one of Europe's most established digital asset centres, combining a significant blockchain ecosystem with an established financial-services industry and regulatory framework.
Developments beyond custody are also contributing to that environment.
In 2025, the U.S. Securities and Exchange Commission announced that it would resume processing registration applications from Swiss-based investment advisers following discussions with FINMA regarding access to records and on-site examinations.
The development illustrates a broader trend: digital assets are increasingly operating within interconnected institutional and regulatory frameworks rather than in a parallel financial system.
For Swiss firms, this creates opportunities — but also raises expectations around governance, infrastructure and the people responsible for both.
Hiring for the Next Phase of Digital Asset Infrastructure
The evolution of custody is part of a wider maturation of the digital asset industry.
Technical expertise remains fundamental, but it increasingly needs to coexist with an understanding of risk, regulation and institutional operations.
For employers, that changes the hiring equation. The strongest teams will not simply combine traditional finance professionals with blockchain engineers. They will need people who understand how those disciplines interact in practice.
As custody infrastructure becomes more sophisticated, the talent supporting it is becoming more specialised.
The ability to identify professionals who can bridge regulated financial infrastructure with the technical realities of digital assets may therefore become one of the more important hiring challenges facing the sector.