Opening a business crypto account: preparing the file and controls
Published 04/06/2026 · Updated 08/09/2026 · Houssen Issouf Aly, French chartered accountant
Crypto-assets · Companies · Directors
Practical guidance for companies and directors. Revised on 7 September 2026.
Original article: 2026-06-04 · Houssen Issouf Aly · HODL Consulting
Identify the account holder first
The objective may be customer receipts, conversion or treasury management. Establish who will transact: a company, sole trader or private individual. The account must match actual ownership and use.
A director’s personal account is not an equivalent temporary company account. Equally, a sole trader should not automatically be treated as a separate company: assess the file, use and applicable asset-separation rules in their own context.
Check the contracting entity’s authorisation
Following the end of the French transition on 1 July 2026, an old PSAN reference is insufficient to establish continuing entitlement for the relevant services. Consult AMF guidance and the European MiCA registers for the entity and authorised services. Certain institutions have a specific notification route; checking a brand logo is not enough.
Record the contracting name, country, official service address and activities. Compare them with the register. One entity’s permission does not automatically cover every business using a similar brand.
Prepare consistent evidence
Requirements vary by provider, entity and intended activity. Obtain the current official checklist and reconcile the documents before submission.
- Business identification and registration.
- Constitutional documents and actual activity.
- Ownership chart and beneficial owners under applicable rules.
- Identity and authority of account operators.
- Reference bank account and funds ownership.
- Source of funds, volumes and transaction types.
- Additional evidence for the file’s specific circumstances.
A provider’s documentation threshold is not a universal legal definition of beneficial ownership. Use the verified official onboarding route for the documents.
Set permissions before operating
Identify administrators, transaction preparers, approvers and statement collectors. Examine authentication, user rights and withdrawals. An activation code delivered by email does not establish strong authentication for every action.
Plan absences and staff departures. The accountant can work from agreed exports or read-only access without receiving the secrets controlling funds. Permissions should match each person’s task.
Test the accounting workflow
Before increasing volumes, arrange a limited authorised check of statements and reconciliation. Confirm availability of dates, assets, quantities, counterparties, fees, references and balances. Trace the connection with wallets and the bank.
Fictional example: a company opens an account to convert customer receipts. The director approves transactions, an employee collects exports and the accountant matches payments to invoices. Any incorrectly labelled internal transfer retains its explanation and correction. Responsibilities are established before recurring operations.
Plan exceptions and exit
Ask how records can be recovered if the account closes, the provider changes or a service is suspended. Onboarding time is not universal; do not promise a two-day activation before the provider accepts the file.
What should HODL receive?
The intended holder, objective, existing account inventory, draft contract and an example flow are enough to frame initial questions.
Where next?
Read the wallet-permissions guide and platform-authorisation guide, then discuss the project with the firm.