Insight & Analysis

Crypto adoption requires internal controls and training

Published: Jan 2026

With more cryptocurrency adoption occurring within corporate treasury holdings, there is a great need for internal controls, the definition of strategy and how company accountants will recognise and report the assets. A New York expert in digital currency accounting urges proactive investment in training for the treasury staff.

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As more US companies adopt cryptocurrencies in their corporate treasuries, there is a great need for discipline, internal coordination and training, according to an accounting scholar specialising in blockchain and digital assets.

Sean Stein Smith, an associate professor at City University of New York’s Lehman College, notes that an entire ecosystem of accounting and regulatory experts is now available to guide your corporate treasury staff through the novel and evolving rules for holding digital assets.

How the US federal government may regulate crypto holdings in corporate treasuries “has recently become clearer but remains complex,” Stein Smith told Treasury Today Group. Bitcoin is currently recognised as a commodity, not a security, allowing companies to hold it as an asset without triggering immediate securities law implications.

“For financial professionals contemplating Bitcoin on the balance sheet, the process demands rigorous planning and operational discipline. First and foremost, the corporate strategy must be clearly defined. Is Bitcoin being held as a long-term reserve asset, a hedge against currency devaluation, or as part of a speculative investment thesis? Each scenario requires different governance and risk frameworks,” Stein Smith said. “Internal controls become paramount.”

According to a 2025 survey by Deloitte, one-quarter of CFOs expect to employ digital currency in some fashion within two years. Still, the respondents are primarily concerned about the price volatility of crypto. Their second-greatest worry is the complexity around accounting and controls.

“Despite these concerns, some survey respondents revealed a willingness to move forward,” the Deloitte analysts wrote. A key reason is the ability of the volatile cryptocurrencies to outperform traditional corporate holdings such as US Treasuries.

Stein Smith said the company’s broader strategy should be clearly defined by the executive leadership.

“From a compliance standpoint, companies must ensure crypto holdings do not inadvertently change their legal classification or introduce unforeseen reporting burdens,” the professor explained. “Disclosure policies, investor relations strategies, and board-level risk reviews all need to be realigned to address the unique characteristics of digital assets.”

Comprehensive federal regulation is gradually being developed under a supportive Trump Administration. The Office of the Comptroller of the Currency has started to ease restrictions, for example. The GENIUS Act created a framework for eventual stablecoin adoption.

The Financial Accounting Standards Board (FASB) allows companies “to reflect both gains and losses from Bitcoin holdings at fair market value directly in earnings — providing a more accurate and less punitive reporting structure than the prior impairment-only model.” Stein Smith mentioned.

“However, regulatory thresholds still exist,” he added. “If a company’s financial assets exceed certain limits, it may be classified as an investment company, triggering a host of new regulatory requirements. Additionally, any unrealised gains could create future tax liabilities under evolving corporate tax rules.”

While federal policy signals that cryptocurrency usage will be encouraged, Stein Smith reminds corporate treasurers that internal controls and proper recognition are needed.

“Organisations need to implement secure custody solutions, establish multi-signature wallets, and create clearly defined access controls to prevent internal fraud or errors,” he warns. “Accounting treatment must be updated to reflect FASB’s fair-value rules, and tax planning must take into account potential implications of mark-to-market reporting and alternative minimum tax exposure.”

Companies must invest in training for the treasury and audit teams, according to Stein Smith. There needs to be coordination amongst the finance, compliance, technology and risk management functions.

“The right training and expert guidance can make the difference between a bold strategy and a costly misstep,” Stein Smith observes.

“To meet this demand, a growing ecosystem of crypto-accounting training programmes, advisory services, and tailored resources has emerged,” he said. “Specialised courses and certifications are now available for CFOs and accounting professionals, focusing on digital asset classification, crypto tax strategies, internal control systems, and blockchain audit readiness. Leading consulting firms and fintech platforms are also publishing detailed playbooks for managing the integration of crypto into corporate finance operations.”

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