Digital Asset Treasuries: The New Balance Sheet Bet – And The Compliance Gap
Corporate treasuries are quietly transforming. What began as a handful of high-profile Bitcoin bets has become a structural shift in how companies think about balance sheets, liquidity and risk.
Recent market and legal research suggest that more than two hundred public companies worldwide have now announced digital asset treasury strategies, collectively holding around one hundred forty-eight billion dollars’ worth of Bitcoin, Ether, stablecoins and other tokens on their balance sheets. A growing subset of these are now explicitly positioning themselves as Digital Asset Treasury Companies (DATCOs): public firms whose core strategy is to raise capital and accumulate digital assets as long-term, “permanent” reserves, rather than treating them as a side allocation.
At the same time, the regulatory environment in the United States, the European Union, the United Kingdom and the Gulf has moved from observation to action. In the United States, new accounting rules require many crypto assets to be held at fair value through profit and loss, rather than under impairment-only models. The Internal Revenue Service has finalized broker reporting obligations that will put far more digital asset transaction data into tax reporting from the 2025 tax year. The GENIUS Act has established the first federal framework for payment stablecoins, with licensing, reserve and disclosure obligations for issuers.
In the European Union, the Markets in Crypto Assets Regulation (MiCA) is coming into full effect, creating a single rulebook for crypto issuers and service providers across the European Economic Area. MiCA’s scope covers transparency, authorization, governance and, critically, a dedicated title on market abuse and insider dealing in crypto markets.
The United Kingdom’s Financial Conduct Authority (FCA) has already brought “qualifying crypto assets” into the financial promotions regime and is preparing to bring a broad range of crypto activities under its core regulated perimeter.
In Dubai, the Virtual Assets Regulatory Authority (VARA) has implemented a detailed framework with mandatory licensing for virtual asset service providers and separate rulebooks on market conduct, compliance, risk management, custody, exchanges and more.
Taken together, the message is clear: digital assets have become strategic treasury instruments, the rules are catching up, and compliance cannot lag behind.
What Is a Digital Asset Treasury?
A Digital Asset Treasury is best understood as a deliberate, structured treasury strategy. It is a corporate or fund treasury function that actively acquires, holds and manages digital assets as part of its liquidity, reserve or capital allocation decisions. Those assets might include cryptocurrencies such as Bitcoin and Ether, stablecoins used for liquidity and settlement, and tokenized versions of traditional instruments such as Treasury bills, money market funds, short-term credit and equities.
A Digital Asset Treasury Company (DATCO) goes further. Legal and market commentary now uses this term for public issuers whose balance sheets intentionally hold large digital asset positions and whose explicit strategy is to keep raising capital and accumulating these assets as long-term reserves. In other words, the digital asset strategy is central to the business model, not incidental.
For compliance teams, this distinction matters. A DAT strategy turns digital asset activity into material, market-sensitive information that can move both the token and the issuer’s own stock. That brings these treasuries directly into the world of securities law, insider dealing and market abuse.
Why Treasury Functions Are Moving into Digital Assets
From a StarCompliance (Star) perspective, the use cases we see fall into three main categories: balance sheet strategy, operations and liquidity, and strategic signaling.
On the balance sheet side, some companies are using Bitcoin and occasionally Ether as long-term reserve assets, in effect a digital “store of value.” Strategy Inc. (formerly MicroStrategy) is the best-known example, disclosing large Bitcoin holdings financed through equity and convertible debt and explicitly positioning its stock as a Bitcoin proxy. Other firms are less public in their signaling but nonetheless treat digital assets as a diversification tool or inflation hedge.
Treasury teams are also using digital assets to generate yield on short-dated cash. Tokenized Treasury bills, on-chain money market instruments and institutional stablecoin products have become increasingly common tools for parking surplus liquidity, with the aim of maintaining high liquidity while earning a more attractive return than traditional deposits. Major advisory firms now cite yield on tokenized “cash equivalent” instruments as one of the leading digital asset use cases for corporate treasuries.
Operationally, digital assets are becoming working capital in on-chain business models. Exchanges, Web3 platforms and cross-border payment firms are using stablecoins and other “on-chain dollars” to support instant settlement and round-the-clock cash management. At the same time, more traditional corporates and financial institutions are starting to experiment with tokenized real-world assets—such as tokenized Treasury bills, short-term credit and, in some cases, tokenized equities—tapping into liquidity pools that are already measured in the billions of dollars and growing quickly.
Finally, there is a signaling dimension. Some issuers, such as Strategy and Metaplanet in Japan, are explicit that their equity is intended to be a high-beta proxy on the digital assets they hold, and research suggests that Digital Asset Treasury Companies can trade at a premium to the value of their underlying holdings as investors treat the stock as levered exposure. Crypto-native firms also often hold their own tokens or governance assets in treasury to align incentives with users and investors. That can be powerful from a product and ecosystem perspective, but it raises immediate questions about volatility, conflicts of interest and insider information.
How We Got Here
The evolution of Digital Asset Treasuries has been relatively fast but follows a clear trajectory.
- Before 2020, corporate use of Bitcoin and other crypto assets was sporadic and largely experimental. Questions about accounting treatment and the lack of institutional-grade custody meant most treasurers watched from the sidelines.
- The period from 2020 to 2021 changed that. MicroStrategy’s aggressive pivot into Bitcoin as a treasury reserve asset—and the visibility that followed—cemented the idea that “crypto on the balance sheet” could be a legitimate corporate strategy. Other firms, including Tesla and Block, followed with their own allocations.
- The 2022–2023 crypto bear market, combined with high-profile failures like FTX, forced a reality check. Volatility, counterparty risk and governance gaps were laid bare. Tesla’s purchase of approximately one and a half billion dollars’ worth of Bitcoin, followed by substantial disposals in 2022, became a widely cited cautionary case on timing, disclosure and alignment with broader corporate risk appetite.
- From 2024 onward, the landscape began to institutionalize. Accounting standards setters, tax authorities and regulators started to provide clearer frameworks. Fair value accounting for qualifying crypto assets reduced some of the balance sheet ambiguity in the United States. Broker reporting rules, MiCA in the EU, the UK’s crypto promotions regime and Dubai’s VARA framework all pointed in the same direction: digital assets could be part of the system, but they would live under recognizable market integrity, anti-money laundering and consumer protection expectations.
Meanwhile, data from public trackers indicates that public companies alone now hold more than one million Bitcoin, with governments and funds holding significant additional amounts. Treasury desks are no longer spectators. They are meaningful participants in digital asset markets.
The Overlooked Risk: Market Abuse, Insider Trading and Front Running
When organizations discuss Digital Asset Treasuries internally, the focus tends to be on volatility, accounting, cybersecurity and classification. Those are valid concerns. But in our work at StarCompliance, we consistently see another risk cluster that is under-developed: market abuse, insider dealing and front running.
This is also the area where global rulebooks are converging most visibly. MiCA’s Title VI is dedicated to preventing and prohibiting market abuse in crypto markets, including insider dealing, unlawful disclosure and manipulation.
The UK’s Financial Conduct Authority is using its promotions regime and supervisory powers to police misleading or irresponsible behavior in crypto markets and has already taken action against unregistered overseas exchanges.
Dubai’s VARA has a specific Market Conduct Rulebook and compliance requirements aimed at ensuring fair dealing across exchanges, broker-dealers and other virtual asset activities.
Against this backdrop, Digital Asset Treasury strategies create three overlapping conduct risks.
First, Digital Asset Treasury decisions are inherently material and often non-public. Choices to raise capital to buy more Bitcoin, to rotate reserves into a particular tokenized Treasury platform, to exit a position or unwind collateral, or to use digital assets to secure significant financing are all events that can move the prices of both tokens and the issuer’s own securities. If employees, executives or close advisers trade ahead of these moves, whether in tokens, the company’s stock or related exchange-traded products, they create classic insider trading and front-running scenarios, even if the instruments are new.
Second, treasury activity itself can move markets. Large, highly public purchases and declarations of long-term holding can contribute to momentum on the way up. Conversely, treasury-funded token launches or unlock events can function as mass exit mechanisms for previously locked tokens, changing circulating supply and putting pressure on prices. Analysts have already argued that, in aggregate, some Digital Asset Treasury structures have operated more as liquidity exits for insiders than as long-term stewards. That narrative is influencing how regulators and institutional investors view the sector.
Third, there is often a structural gap between treasury and compliance. In many of the firms we work with, treasury teams can move quickly on specialist venues and structures, while existing pre-clearance, restricted list and surveillance frameworks are focused on traditional securities. Compliance tools may monitor only listed equities, fixed income and funds, leaving activity on dozens of crypto exchanges and multiple blockchains largely invisible. That combination produces predictable blind spots: unmonitored employee trading in tokens that mirror listed securities or corporate tokens, incomplete surveillance across tokenized equities and related products, gaps in conflict-of-interest and private investment disclosures where digital wallets are not captured, and weak audit trails for treasury decisions that may later be scrutinized by regulators or investors.
Global regulators are already moving toward applying familiar market integrity principles to digital assets. Executive Order 14067 in the United States, MiCA’s market abuse title, FCA enforcement and Dubai’s VARA rulebooks all point toward a world in which digital assets are treated as part of the same conduct ecosystem as traditional securities, even if the legal labels differ.
Why Compliance Needs to Cover Both Digital and Traditional Assets
Star’s core view is straightforward: once digital assets are part of the balance sheet, they are part of the core securities and conduct risk of the firm. They are not a separate, experimental side project.
Monitoring them properly requires a unified compliance workflow that spans both digital and traditional assets and can adapt to different regulatory regimes, from the United States and the European Union to the United Kingdom, Dubai and beyond. In practical terms, that means a single pre-trade clearance experience for employees across equities, funds, options and digital assets; post-trade surveillance that can ingest data from traditional brokers, crypto exchanges and blockchains; policy and disclosure management that explicitly captures digital asset holdings and wallets; and market abuse analytics that recognize familiar patterns like wash trading, spoofing, layering and pump-and-dump in digital markets while linking them back to trading in the company’s own securities and related products.
Digital Asset Treasuries can help diversify balance sheets, unlock new liquidity and signal innovation to the market. They also create new channels for familiar risks: market manipulation, insider trading, front running and unmanaged conflicts of interest. Boards and chief compliance officers who invest now in integrated technology and workflows, covering both digital and traditional assets, will be better positioned when the next crypto cycle arrives and as global rulebooks continue to converge.
Star is focused on building that bridge between digital assets and traditional finance compliance. If your organization is exploring a Digital Asset Treasury strategy, this is the moment to make sure your surveillance, pre-clearance and disclosure framework can see the whole picture.
To learn more about Star’s Crypto Dealing & Tokenized Asset Compliance Solutions, schedule a personalized demo here.
The Next Chapter in Compliance
