Building a Compliance Register Without Losing Focus
Last week, we tackled key ceremonies and wallet architecture. This week, we take a step back and ask:
“What rules actually apply, and how do we keep track of them?”
My Pilot Reality
In my one-person company, the compliance picture is simple:
- I don’t provide custody or execution for others, so I don’t need an FSCA licence.
- My focus is documenting what I do (wallet setup, governance SOPs, reconciliations), so if an auditor, bank, or investor ever asks, I can show clear records.
This is the Safe Zone. Most companies can adopt Bitcoin into treasury without being financial service providers, provided they keep their house in order.
But the moment a business expands into new markets, new investors, or a regulated activity, the compliance map gets more complex. That’s why a Compliance Register is essential.
Why a Compliance Register Matters
A Compliance Register is just a simple way of keeping track of:
- What rules apply to us right now.
- What rules don’t apply (but we may want to mirror as good practice).
- How we prove we’re compliant (or aligned).
Without it, compliance is reactive. With it, compliance becomes proactive governance. Think of it less as “red tape” and more as a confidence document, something that makes auditors, banks, and investors comfortable.
Safe Zone vs Regulated Zone
Safe Zone (applies to everyone):
- FICA (SA) / AML obligations (EU/UK): basic KYC if you’re dealing with banks or large crypto counterparties.
- IFRS 9 + ISA 500: classify Bitcoin properly and keep sufficient evidence.
- King IV™ (Principles 12 & 15): treat your treasury IT & assets like any other governance priority.
Regulated Zone (only if you custody / execute for others):
- FSCA Conduct Standard 3 of 2025 (SA): safeguard client assets with operational controls.
- MiCA (EU): segregation of assets, resilience standards for service providers.
- FCA (UK): operational resilience rules for crypto asset firms.
Most SMEs will stay in the Safe Zone. But mirroring aspects of the Regulated Zone shows maturity and prepares you for growth.
This Week’s Artifact: Compliance Register Template
I’ve created a simple Compliance Register you can adapt. It helps you track:
- Jurisdiction.
- Regulation / obligation.
- Applicability (Mandatory / Best Practice / Not Applicable).
- Internal control or process in place.
- Evidence on file.
- Review date & responsible owner.
📄 Download Compliance Register Template.
Next Week
We’ll get into Accounting Policy & Month-End Close, and show how to bring Bitcoin into the GL under IFRS 9, and what auditors actually expect to see.
🔗 This is Part 6 of the Bitcoin Treasury Series. Follow the full archive here.