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Are Banks Prepared for Virtual Asset Custody? Insights from the 4th Edition of G.A.I.N. by Liminal Custody

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Virtual asset custody is no longer a fringe consideration for financial institutions. It is one of the most consequential infrastructure decisions banks face right now, and the gap between institutional readiness and market momentum is narrowing fast.

At Liminal Custody’s fourth GAIN (Global Access for Institutional Network) Roundtable, a high-caliber panel explored the regulatory, operational, and technical dimensions of bank-grade digital asset custody. Moderated by Dr. Bhaskar Dasgupta, Chairman of Apex Group and Independent NED at Liminal Custody, the session featured:

  • Bryan Stirewalt, Former CEO of the DFSA and Executive Advisor at Grant Thornton
  • Gebhard Scherrer, Director of Sales at Securosys
  • Muhammad Ali Malik, Head of Strategic Projects at First Abu Dhabi Bank

Here is what the discussion surfaced.

Watch the full session recording: https://youtu.be/7WM3JBNR66w

The Paradigm Shift Banks Can No Longer Ignore

A consistent theme across the panel: virtual asset custody is not an incremental product extension. It represents a structural shift in how financial value is created, stored, and moved.

Bryan Stirewalt framed it directly: banks that are still trying to fit digital assets into legacy frameworks are misreading the moment. Traditional custody was built for a world where “big and boring” was enough. Digital asset custody demands agility, specialist talent, and a willingness to engage with an ecosystem that is evolving faster than regulatory cycles can capture.

For banks still on the sidelines, the commercial argument is becoming difficult to ignore. A significant share of UAE residents now hold digital wallets. Family offices globally have meaningful virtual asset allocations. Corporates are using stablecoins for cross-border payments, reserve management, and liquidity optimization at a speed that six-hourly deposit instruments simply cannot match. Inaction is a market share decision.

Regulatory Clarity Is Creating Urgency, Particularly in MENA

The UAE’s regulatory posture is accelerating the conversation. Stirewalt noted that the Central Bank of the UAE, alongside VARA, DIFC, and ADGM, has built one of the most progressive digital asset regulatory ecosystems globally. The approval of First Abu Dhabi Bank’s stablecoin initiative by the central bank is a direct signal that regulated institutions can now operate meaningfully in this space.

For banks operating across multiple jurisdictions, Stirewalt’s guidance was clear: do not wait for global regulatory convergence. Engage proactively with regulators, build internal expertise, and treat compliance teams as functions to be empowered, not just consulted.

Security Infrastructure Is the Non-Negotiable Foundation

Gebhard Scherrer brought the technical dimension into sharp focus. Hardware Security Modules (HSMs), the same technology that underpins SWIFT messaging and credit card verification, are the trust anchor for any institutional-grade digital asset custody deployment.

The point Scherrer returned to repeatedly: cryptographic keys must live inside tamper-resistant hardware, not on servers. Many of the high-profile exploits in the digital asset space trace back to keys stored outside of hardware. For banks building custody infrastructure, hardware-rooted key protection with rigorous segregation of duties is not optional. It is the baseline.

Beyond the initial build, Scherrer emphasized the importance of operational resilience. HSMs should be deployed in clustered pairs across multiple jurisdictions, with verified backup and recovery protocols tested before they are ever needed. A custody solution is only as strong as its recovery plan.

On post-quantum readiness, Scherrer noted that while quantum computers are not yet a live threat, banks should begin inventorying their key assets and testing migration pathways to NIST-approved post-quantum algorithms now. The transition is a multi-year program, and the preparation window is shorter than most institutions recognize.

Build vs. Buy: A Hybrid Approach Is Emerging

The panel reached consensus on the build-versus-buy question. Banks should own the core trust anchor, the governance layer, and the cryptographic infrastructure. They should partner for wallet orchestration, policy engines, and application-layer tooling. Reinventing the wheel is expensive, slow, and unnecessary when mature infrastructure providers bring cross-institutional implementation experience to the table.

The Immediate Priority: Cyber Resilience First

When asked what a bank planning to go live with digital custody within twelve months should prioritize first, both Stirewalt and Scherrer aligned: cyber resilience and hardware infrastructure. Everything else, compliance workflows, product design, client onboarding, is built on top of that foundation.

The message from the GAIN Roundtable was consistent: the window for deliberation is closing. Banks that move now, with the right infrastructure, the right partners, and the right internal architecture, will be positioned to capture a market that is already in motion.

Ready to build institutional-grade digital asset custody infrastructure? Connect with our team to get started

Liminal Custody is an institutional digital asset wallet infrastructure company, enabling banks, exchanges, and fintechs to build and operate secure, compliant custody infrastructure at scale.

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