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Annual Crypto & Compliance Survey 2024

Find out how financial service firms around the globe are approaching employee crypto-trading from a compliance perspective in Star’s annual market survey

Introduction

Star continues its thought leadership to have a better understanding on how financial services firms around the globe are approaching employee crypto trading from a compliance perspective with their fourth annual Crypto and Compliance survey. 

Survey
Demographics

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* Fintech, Government Pension, Real Estate, Insurance Company, Advisory, Retail Bank, Federal Regulator

Does your firm have an employee crypto trading policy in place? 

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Of the 1/3 of firms with a crypto trading policy in place, over 58% of those firms have implemented it in 2024. Alarmingly, among firms without a policy, the same percentage have no plans to adopt one in 2025. 


If your firm already has an employee crypto trading policy in place, when was it implemented?
  • In the last 12 months: 58.3% 
  • 1-2 years ago: 11.11% 
  • 3-4 years ago: 19.4% 
  • More than 4 years ago: 11.11% 

A significant majority (58%) of firms have only implemented an employee crypto trading policy within the past 12 months, highlighting the relatively recent prioritization of compliance in this evolving space. While digital asset trading is becoming more established, many organizations are still in the early stages of formalizing their oversight, indicating a need for continued regulatory adaptation and risk management. 

If you don’t have an employee crypto trading policy in place, are you planning to implement one in 2025? 

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Forty-one percent of respondents who have not yet implemented an employee crypto trading policy intend to do so in 2025. This is trending in the right direction from our findings in our 2023 Crypto and Compliance Market Study, but there are still nearly 60% of firms that have no implementation plans. 

Firms must assess their preparedness as regulatory scrutiny intensifies.

Many crypto trading policies now require employees to pre-clear crypto transactions like other securities, prohibit crypto mining and ICO participation, and disclose crypto holdings in anticipation of future regulations. While adoption has increased, the urgency is growing with the EU’s MiCA framework taking effect and the SEC’s new Crypto Task Force signaling heightened enforcement. Firms without a policy risk falling behind in an evolving regulatory landscape. 

Thirty-six percent of firms without a dedicated crypto trading policy stated that their existing conflicts of interest policies already cover trading in both traditional securities and digital assets, making a separate policy unnecessary. Others cited that crypto assets are included in their broader trading policies for securities, with certain exemptions, eliminating the need for a standalone policy. 

These findings align with trends observed in the first three years of our survey (2021-2023), where firms reported updating their compliance policies to include digital assets and, in some cases, requiring employees to pre-clear all trades. 

How confident are firms’ knowledge of their employees’ crypto activities in their personal accounts?

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The number of people “not at all confident” in their understanding of how employees are trading crypto instruments in their personal accounts increased 11% year-on-year. This was surprising considering the increased level of focus regulatory bodies around the globe have been giving crypto and digital assets.  

In addition to this, those who are “very confident” decreased by 8% year-on-year. This suggests that additional focus, resources and education are needed to increase overall awareness, as well as gain further transparency into this activity.   


What is the approximate age breakdown of your firm’s employees who trade crypto assets? 

Similar to the results of our 2023 Crypto and Compliance Market Study, in 2024 firms identified Millennials (25%) – down from 32% in 2023 – as the generation of employees that trade crypto assets the most. Interestingly, in 2024, the level of understanding on which age groups were trading crypto assets remains in the majority at 52.7% – slightly down from 61% in 2023.  

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What percentage of employees’ tradable assets do you believe are invested in crypto?

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About 40% of respondents estimate that their employees invest less that 25% of their tradable assets in crypto – about the same (45%) in 2023. While it’s important to note that the same small minority (2.7% in 2024 vs 2% in 2023) believe employees invested more than half of their tradable assets in crypto.  In addition, the results highlight that the number of firms not knowing how much their employees’ tradable assets are invested in crypto remained the same at 50%.  

When do you think crypto regulations, such as the MAS stablecoin regulatory framework, the SEC’s aggressive pursuit of the crypto industry in general in the US and MiCA in the EU, will start having an impact on your team or the business as a whole?

33% of respondents expect that regulations and guidance for employee crypto trading activity will come into force in the next 18 months, down 6% vs our 2023 Crypto & Compliance Market Study.  

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How will your firm be monitoring and managing employee crypto trading risks, as their use becomes increasingly widespread?
  • By investing in crypto monitoring software: 25% 
  • Through our current compliance software: 36% 
  • Through Excel or other manual processes: 8% 
  • I won’t be monitoring it: 19% 
  • Other: 11% 

The majority of respondents (60% in 2024 vs 63% in 2023) are looking to monitor and manage employee crypto trading risks by investing in or using compliance/monitoring software, with over one-third (35%) planning to use their current compliance software.  

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