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Case Studies/Vaultline

VASP licensing and key-management security as one operating model

A custody operator expanding into a second jurisdiction needed licensing support, AML controls, and a security review of key management — without a seam between the application and the vault.

ComplianceSecurityMaintenance & ScaleInstitutional digital-asset custodian
License track
VASP
Key controls reviewed
MPC
Travel Rule live
FATF

The challenge

The gap after delivery

Counsel could describe the custody model. A security shop could review the vault. Neither would still be present when the regulator asked how a withdrawal policy had changed in production.

  • License narrative and actual signing-policy code had already drifted.
  • Travel-rule and sanctions screening were specified, not operated.
  • No retained monitoring of the custody stack after the previous assessment.

What Avenza did

One continuous workstream

Avenza wrote the VASP dossier against the live key-management architecture, then kept security and compliance on retainer through the authorization period.

  • Reviewed MPC / HSM controls, approval policies, and operational access paths.
  • Aligned the license application with withdrawal, incident, and records procedures as they actually run.
  • Implemented AML/KYC and travel-rule operations for inbound and outbound transfers.
  • Retained a maintenance desk for policy changes that would otherwise reopen license risk.

Outcomes

Cover that did not end

Vaultline could show a regulator — and its own clients — that security and compliance were the same operating relationship.

  • Application dossier matched production signing and incident procedures.
  • Travel-rule obligations evidenced with operating logs, not a policy PDF.
  • Key-management findings remediated before the authorization interview.
  • Retained Avenza cover used in enterprise client RFPs.

“The license is a snapshot. The vault keeps changing. We needed the partner who stays for both.”

Chief Risk Officer—Vaultline

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