GRCLibrary.ai

Oversight Question Set

What the governing body should ask about the organization's crypto-asset classification, custody, reserves, disclosure, providers, and smart-contract risk

A leadership page from the library's executive layer: it explains the position in plain language, and the corpus documents it cites remain the governing texts.

Read the source on GitHub (opens in a new tab)

Authority disclaimer. This page is an executive narrative. It does not establish requirements; the linked corpus governs. It is provided to support understanding, discussion, and decision-making by the governing body and accountable executive leadership (board, ELT, or senior management, as applicable). It creates no obligation, control, or assurance by itself. Its publication approval is an editorial act only and confers no authority over any corpus document. Where it differs from a corpus document, the corpus document prevails.

§01

Context for these questions

Each question below is paired with the operating evidence a strong answer produces, and routes to the corpus document that governs it. The method is deliberate: a governing body learns more from the evidence a control actually generates than from an assurance that the control exists. A described control the organization cannot evidence is not demonstrably operating. The questions are grouped by the governance exposures the crypto corpus is built around; a strong answer to any of them reads from a live record, not a summary of one.

§02

Questions

Theme: classification and approval. Do we govern crypto activity before it starts?

  • For every crypto-asset activity we run, was the asset classified and the activity approved before it began? A strong answer produces the crypto-asset inventory entries showing the classification result and the activity-approval record dated before the activity started, which the crypto-asset governance framework makes the precondition in its governance requirements (no asset issued, offered, custodied, traded, or used before it is classified and approved).
  • How would we find crypto activity that never came through the approval gate? A strong answer describes a control operating, not a policy forbidding it: the reconciliation of the inventory against on-chain balances and platform accounts that the inventory register maintains as its authoritative record.

Theme: custody. Are client and proprietary assets safeguarded and segregated?

  • Can we show client crypto-assets are segregated from our own and beyond our creditors' reach? A strong answer produces the custody policy, the on-ledger separate positions, and the legal-segregation basis the digital-asset custody standard requires (its segregation and register-of-positions sections).
  • Can no single person move client assets, and are custody keys under the key-lifecycle controls? A strong answer shows the split-knowledge and dual-control evidence and the key-lifecycle records the custody standard sets for wallet tiering and key custody.

Theme: reserves and redemption (stable-value tokens). Is the backing real and matched to claims?

  • If we issue a stable-value token, is the reserve constituted, segregated, independently audited, and matched to holder claims? A strong answer produces the reserve policy, the segregation evidence, and the independent reserve-audit result the reserve and prudential standard requires (its reserve-constitution and segregation sections).
  • Do we hold recovery and redemption plans for the token's stressed and end-of-life states? A strong answer produces the notified recovery plan and redemption plan the reserve standard requires (its recovery-and-redemption-plan section).

Theme: disclosure and filings. Are holders informed and authorizations current?

  • For each public offer or admission, is there a compliant, current white paper on the right lifecycle path for the asset class? A strong answer produces the white paper and its notification, approval, or publication record on the class-appropriate path the white-paper content and disclosure standard sets.
  • Are our authorizations current, and are the ongoing regulatory obligations maintained? A strong answer produces the submission file and the log of maintained records, policies, and notifications the regulatory-submission standard sets.

Theme: providers and smart contracts. Are dependencies vetted and controlled?

  • For each crypto-asset service provider we rely on, did the authorization gate pass; and for each deployed or relied-on smart contract, is the upgrade or change authority named and controlled? A strong answer produces the provider authorization and vetting record the service-provider vetting standard requires at its legal-identity-and-authorization gate, and the deployment and change-governance record the smart-contract and oracle risk standard sets for immutability-aware deployment and upgrade governance.

A weak answer in any theme: an assurance in place of a record. "We hold mostly the same assets as last year" with no classification date; "the custodian handles segregation" with no evidence the organization verified it; "the reserve is fine" with no independent audit; a white paper that was published once and never updated as the offer changed.

§03

Evidence to request

  • The crypto-asset inventory with per-asset classification and pre-activity approval, reconciled against on-chain balances.
  • The custody policy, the register of positions, and the key-custody split-knowledge and dual-control evidence.
  • For each stable-value token, the reserve composition, the independent reserve-audit result, and the recovery and redemption plans.
  • The white-paper record and its notification, approval, or publication evidence for each offer or admission.
  • The provider authorization and vetting records, and the smart-contract deployment and change-governance records.
§04

Limitations

This page is a non-normative executive narrative that creates no compliance by itself; the linked corpus documents govern, and where this page and a corpus document differ, the corpus document prevails. It routes to the corpus rather than reproducing its values: the thresholds, coverage ratios, clocks, retention periods, key-management assurance levels, application timelines, and classification definitions live in the linked standards and are not restated here. Whether a given obligation attaches, and under which regime, is the organization's own fact-dependent determination.

Source

The source

This page is rendered from the version-controlled Markdown file in the corpus repository, with the site's navigation and framing added around it. The Markdown, where its metadata, review record and full history live, is the source. If the two ever differ, the source governs.

Domains

The domains behind it