Coinbase Doesn’t Custody All of Strategy’s Bitcoin—So Who Does?

Bitcoin treasury giant Strategy has always been coy about naming its BTC custodians. But people outside the firm do know who they are.

For starters, Strategy has repeatedly cited its “various custody arrangements”—there is no one exclusive custodian that’s holding onto its nearly $72 billion worth of BTC on the company’s behalf. A spokesperson for Coinbase confirmed it is one of Strategy’s custodians when asked by Decrypt—but stressed that MSTR has previously named Coinbase as one of its custodians.

Strategy did not immediately respond to a request for comment from Decrypt on its decision to withhold the names of its custodians.

The issue of Strategy’s Bitcoin holdings, and who exactly holds the keys to the $72 billion stockpile, was brought to the fore recently following controversial statements by the company’s founder Michael Saylor. Back in May, Saylor said it was a “bad idea” to publicly share “proof of reserves” or otherwise provide a detailed list of custodians, citing security concerns.

Skeptical crypto market observers, many of whom lived through the contagion-inducing blowups of FTX, Three Arrows Capital, Celsius, and others, criticized Saylor at the time for refusing to share these details—though others supported the cautious approach to operational security. The matter reentered public discourse two weeks ago when Coinbase CEO Brian Armstrong proudly boasted on X that his company custodies Bitcoin for eight of the 10 publicly traded BTC holders—strongly implying Coinbase is one of Strategy’s custodian.

Armstrong’s tweet, however, may not have been as controversial as some initially interpreted. According to Coinbase, Saylor had already previously named Coinbase as one of its custodians. After all, Strategy—formerly MicroStrategy—is a public company, trading under the ticker MSTR, so some amount of disclosure is expected.

Indeed, Strategy disclosed details about its custodians to the SEC in an April 2023 letter. The regulator wrote to Strategy on April 5, 2023, to pointedly ask how “recent bankruptcies in the crypto industry and failures of certain financial institutions, and the downstream effects of such events, have impacted or may impact your business.”

At the time, the industry was reeling from FTX’s $8 billion collapse. Then Silvergate Bank and Signature Bank were forced to wind down their operations in March. The whole period left regulators and shareholders wondering whether Strategy’s BTC was still safe—particularly because Strategy had used some of its BTC as collateral for a loan from Silvergate.

But when Strategy replied two weeks later, answering the SEC’s request to “please tell us the names of your custodians,” the company invoked SEC Rule 83 to keep the details confidential.

What was left public is that Strategy keeps its Bitcoin in accounts at “U.S.-based, institutional-grade custodians that have demonstrated records of regulatory compliance and information security, and all of our custodians are New York Department of Financial Services (“NYDFS”)-regulated custodians.”

That’s descriptive enough to whittle down the list of probable custodians.

Of the 35 recipients of NYDFS BitLicenses, only 9 had limited purpose trust charters when Strategy sent its letter in spring of 2023. Those include BitGo, Coinbase, GMO-Z.com, Fidelity, Bakkt, Gemini, NYDIG, Paxos, and Standard Custody & Trust Company.

Coinbase isn’t a big surprise, especially because the exchange has often been cited in MSTR filings as its “principal market for Bitcoin.” In fact, Strategy did its first-ever Bitcoin buy through Coinbase.

Meanwhile, blockchain analytics platform Arkham Intelligence claims to have traced 70,000 worth of the company’s BTC to Fidelity in May.

The company hasn’t confirmed that it holds some of its BTC with Fidelity, but the firm does fit the profile for being on the list. A source familiar with Fidelity Digital Asset Services business told Decrypt the firm takes its clients’ security very seriously and wouldn’t disclose—directly or indirectly—its clients’ information.

There’s a few under-the-radar companies on the list of potentials, too.

GMO-Z.com is the U.S. subsidiary of GMO Internet Group, a large Japanese internet conglomerate that owns Onamae domain registration, web hosting, payments, and a crypto exchange and mining business. It’s also the issuer of GYEN, which it calls the first regulated Japanese YEN stablecoin, and ZUSD, a U.S. dollar-pegged stablecoin.

It’s unlikely GMO-Z holds any of Strategy’s Bitcoin because the company explicitly says it custodies reserves in GYEN or ZUSD, its U.S. dollar-pegged stablecoin.

The Standard Custody & Trust Company, which Ripple acquired in June 2024, was a subsidiary of PolySign. PolySign was co-founded by Ripple co-founder Arthur Britto, Ripple Chief Technology Officer David Schwartz and is led by CEO Jack McDonald. McDonald is also the SVP of Stablecoin at Ripple.

Standard Custody has gone out of its way to fly under the radar, positioning itself as an institutional grade, white-label custodian.

Bakkt Trust Company is also on the list. Former parent company Bakkt has been many things over the years. In 2019, Bakkt acquired Digital Asset Custody Company and landed a limited purpose trust charter—making it one of the earliest firms to become an NYDFS-regulated Bitcoin custodian.

But the company sold its custody business to its parent company. Neither Bakkt nor Intercontinental Exchange responded to a request from Decrypt about whether the custody business still has clients.