At a fund, the portfolio manager or chief investment officer usually holds budget authority, but the chief compliance officer, operations lead, legal team, risk officer and custodian must approve a DeFi product before any money moves. At a corporate treasury, the treasurer or CFO decides, with tax, accounting, legal, risk and the bank as checkpoints.
Who signs the contract at a fund?
The portfolio manager or CIO signs once every control function has cleared the product. Registered investment advisers must hold client funds and securities with a qualified custodian under Rule 206(4)-2, so the custodian's relationship manager is part of the buying process from the first call. In September 2025 an SEC commissioner's statement confirmed that the custody provisions cover advisers' client crypto assets and the crypto holdings of regulated funds, which brings the fund board into the decision too.
On 3 September 2024 the SEC charged Galois Capital for custody failures. The adviser had held a private fund's crypto assets on trading platforms including FTX, and about half of the fund's assets were lost when FTX collapsed. Expect the compliance officer and the operations lead to ask how your product avoids that outcome before they look at the yield.
A portfolio manager can champion your product. Closing it takes materials written for compliance, operations and the custodian, delivered early.
Who controls the budget at a corporate treasury?
The treasurer or CFO holds the budget. Standard Chartered named staking, lending and liquidity provision in DeFi as possible treasury strategies in September 2025. Treasurers who act on that work with cash management, banking, risk and legal teams.
Corporate treasuries often reach DeFi through a bank, custodian or regulated provider they already use. In April 2025 Standard Chartered and OKX announced a collateral mirroring programme that lets financial institutions use tokenised money market funds and crypto as off-exchange collateral, with Franklin Templeton taking part. For a protocol, a structure like that puts the bank's own onboarding and due diligence team between you and the treasurer.
What does the compliance officer need to see?
The compliance officer needs three things:
- Proof that the product fits the fund's existing custody arrangements.
- Evidence that counterparty risk is measured and monitored, with named entities.
- Confirmation that using the product needs no new regulatory filing or exemption.
Prepare a one-page custody architecture diagram, a counterparty risk matrix and a log of regulatory changes that affect the product before the first compliance meeting. Allocators run a similar screen on the protocol itself; our allocator metrics guide lists what they check.
Who holds veto power?
At a fund, the custodian and the board can stop a deal. On 1 October 2026 the SEC proposed custody rules that would let a regulated fund self-custody crypto assets through its adviser only if the adviser meets the self-custody conditions and the fund's board oversees the arrangement. The proposal is not final. Until it is, assume the board reviews any custody design that departs from a qualified custodian.
At a corporate treasury, the primary bank has an informal say. A treasurer has little reason to adopt a product that complicates that relationship. The SEC's September 2025 remarks on custody put custody at the centre of institutional confidence. For a DeFi product sold to either buyer, the owners of custody, counterparty risk and regulatory controls act as gatekeepers even when the investment case starts with the CIO.
Which title should you contact first?
Contact the portfolio manager at a fund and the treasurer at a corporate treasury. In the same week, send separate introductions to the head of operations and the chief compliance officer. A sale that runs through one person stalls when that person meets their first objection.
| Buyer type | First contact | Parallel contacts | What the parallel contacts need |
|---|---|---|---|
| Regulated fund | Portfolio manager or CIO | CCO, head of operations, custodian relationship manager, fund board | Custody design, counterparty matrix, reporting format |
| Corporate treasury | Treasurer or CFO | Head of cash management, tax director, legal counsel, risk officer, banking partner | Accounting treatment, tax position, bank compatibility |
| Family office | CIO or investment committee chair | Legal adviser, tax adviser, custodian | Legal structure, tax position, custody design |
In 2024 Standard Chartered announced an institutional digital asset custody service in the UAE, offered alongside its custody, financing and banking services for traditional assets. When a fund or treasury buys DeFi access through a provider like that, the provider's onboarding team becomes one more approver.
How do you map the buying committee?
- Search LinkedIn for the fund or treasury name plus each title: portfolio manager, CIO, CCO, head of operations, treasurer, CFO, head of legal, head of risk.
- Confirm each job title on the company website or in a recent press release. Our guide to finding the buyer's name and email covers this step without paid data tools.
- Ask your first contact who else signs off. One question works well: "Who else needs to approve the custody design before we can move forward?" The answer usually names the custodian relationship manager and the board contact.
- Send each approver a one-page summary for their function. The portfolio manager gets the investment case and performance data. The CCO gets the custody and compliance summary. The operations lead gets integration and reporting documents. The custodian gets the technical architecture and the API specification.
Buyer committee checklist
Before you email a fund or treasury, confirm each item:
- You know the portfolio manager or treasurer by name.
- You know the CCO or head of compliance by name.
- You know the head of operations or the custodian relationship manager.
- You have a one-page custody architecture diagram.
- You have a counterparty risk matrix with named entities and exposure limits.
- You have a log of regulatory changes from the past 12 months.
- You have confirmed the product needs no new regulatory filing or exemption.
- You have a reference customer in the same jurisdiction.
The Diagnostic at $2,500 names the titles at funds and treasuries who take the first meeting and ranks the accounts that fit now.