Proof of Reserves, Custody, and Auditing

Solutions for Achieving Security and Trust in Cryptocurrency Exchanges
With the ever-evolving nature of the cryptocurrency industry, specialized online exchanges and new traders enter the market constantly. This rapid growth has led to various challenges and problems. A significant portion of these issues arises directly when operational costs are covered by users’ funds, or when users and traders suspect such practices. Misconceptions or challenges of this kind can be addressed and remedied with solutions such as proof of reserves, custody procedures, and auditing. Simply put, an exchange can demonstrate that it preserves users’ funds by having sufficient assets and offering reports and control mechanisms. This increases levels of trust and helps avoid situations where users’ withdrawals need to be restricted (usually caused by fund shortages). These solutions gained more attention following the collapse of the FTX exchange. In this article, we aim to discuss these three solutions.
Table of Contents
What is Proof of Reserves (PoR)?
Proof of Reserves (PoR) is a cryptographic mechanism used by centralized exchanges to demonstrate that they have sufficient reserves to back 100% of their customers’ funds. This mechanism reassures users that their funds held with the exchange are backed, or at the very least, that the exchange can fulfill all withdrawal requests based on the reserves (either physical or non-physical).
In essence, PoR involves comparing the total liabilities of the exchange to the total reserves it holds (i.e., the assets maintained by the exchange). The goal is to ensure that assets match or exceed liabilities so that debts can always be paid, reducing fears of default, bankruptcy, or mismanagement among users.
Components of Proof of Reserves
The PoR process typically involves several components working together to provide transparency without compromising user privacy or security. These components include:
1. Merkle Tree
Cryptographic structures like Merkle trees are often used in the exchange space to allow users to verify their account balances without accessing other users’ data. This tree-like structure displays the levels of liabilities and assets, enabling anyone to see the financial surplus or deficits of the exchange at any time compared to its reserves. Since this structure operates on a blockchain network, tampering or creating fictitious financial statements is not possible.
2. Public Proof of Reserves
To enhance transparency, some exchanges also showcase their wallet addresses on the blockchain. This allows users and other stakeholders to monitor all the assets the exchange stores during its financial operations. Users can verify the amounts of Bitcoin or other cryptocurrencies stored by exchanges through the published wallet addresses.
3. Third-Party Auditing
In addition to cryptographic tools, some exchanges include third-party audits, where independent auditors review the exchange’s existing assets. These audits compare the reserve amounts in wallets with the owed funds to customers. Independent audits ensure the integrity of the PoR process, especially the managerial mechanisms, and also increase confidence in the absence of manipulation.
Operational Steps of Proof of Reserves
To execute PoR transparently, accurately, and privately for each user, several steps are involved. The verification process often includes the following:
1. Snapshot of Liabilities
The system takes a snapshot of all user assets (including liabilities and balances). This snapshot reflects the total credit owed to each customer, whether in cryptocurrencies or various fiat currencies.
2. Building a Merkle Tree
The exchange hashes each user’s balance into a Merkle tree, enabling efficient and private verification. Each user can submit their balance hash, which can then be used to verify that their balance is included in the total liabilities, without revealing the complete list of their deposits.
3. Proof of Reserve Disclosure
The exchange often publishes its reserve in the form of wallet addresses on the blockchain. This type of transparency gives users and auditors the opportunity to confirm the actual reserves held by the exchange. Thanks to blockchain’s public data, anyone can verify the total reserves in the exchange’s wallets.
4. Third-Party Auditing
A third-party auditor, an independent and experienced individual or group, is regularly hired by exchanges to thoroughly review all data and documents related to reserves and the exchange’s financial practices. The exchange must ensure the auditors’ independence and immunity (this is typically recommended to be performed blind and outsourced). Auditors compare the liabilities—often users’ deposits—with the chain-based reserve assets held by the exchange to check whether the payment balance is in a suitable state. In other words, if the reserve equals or exceeds liabilities, the exchange successfully passes the audit.
5. User Verification
After audits, users can independently verify their balances. Using the Merkle tree, users can confirm that their balance is included in the total liabilities without exposing their individual data.
Challenges
While PoR is a promising solution for increasing transparency, its implementation comes with challenges. These challenges include:
1. Invisible Liabilities
One of the major limitations of PoR is its tendency to focus only on reserves. As a result, exchanges may complete the PoR process with little or no disclosure of off-chain liabilities. However, there might be other liabilities, such as loans, salaries, and operational costs, that are not explicitly reflected in the financial statements. This means the risk of default or bankruptcy remains non-zero, as off-chain liabilities could be large enough to threaten solvency, even when all measures suggest adequate reserves.
2. Lack of Standardization
While this approach may seem ideal, there are currently no accepted standards for implementing and developing PoR across different exchanges. It is also not reflected in accounting guidelines. This, in turn, makes it difficult for users to compare PoR results across exchanges. The lack of standardization also opens the door for manipulation, allowing an exchange to selectively present data to appear consistently satisfactory.
3. Real-Time Data Updates
PoR often relies on snapshots taken at specific moments. However, the crypto markets change rapidly, and the financial status of an exchange could shift within hours. Real-time or frequent updates are not provided or feasible, creating a false sense of security for users, as significant fluctuations in reserves could occur between snapshots.
4. Complexity for Users
When advanced cryptographic techniques like Merkle trees are used, PoR might be complex for ordinary users. Due to the complexity, most users do not fully understand how to verify their balances or what PoR audits mean for the security of their funds. This could reduce confidence in PoR, as users may be overwhelmed by the technical nature of the process.
5. Costs and Operational Burden
Implementing PoR requires technical expertise as well as financial resources. Smaller exchanges may struggle to allocate the budget needed for regular audits, establishing secure infrastructure, and ensuring accurate reporting. The cost of conducting frequent audits and maintaining transparency could be high, potentially resulting in higher upstream fees for users.
Proof of Reserves Examples

A large number of exchanges have started implementing proof-of-reserves methods to enhance transparency and build user trust. Some well-known examples include:
Kraken Exchange:
Kraken was one of the first major exchanges to introduce proof of reserves. It regularly publishes third-party audits and uses Merkle Tree structures, enabling users to independently verify their account balances.
Binance Exchange:
Following the collapse of FTX, Binance accelerated its implementation of a proof-of-reserves plan by publishing wallet addresses and collaborating with third-party auditors to verify its reserves. Binance also aimed to educate its users on how to independently verify their funds through the proof-of-reserves process.
Custody Solutions
Custody or storage solutions aim to protect users from specific risks such as cyberattacks, hacking, unauthorized access, and fraud. These solutions increase the security of individuals’ assets and boost their confidence in exchanges and centralized financial tools.
In custody and storage solutions, a portion of users’ assets is held securely by exchanges, using various plans and technologies to minimize risks to an acceptable level. This allows for a balance between liquidity and smooth trading operations. Notably, centralized exchanges apply these solutions for major cryptocurrencies such as Bitcoin and Ethereum, as well as a limited number of altcoins.
Types of Custody Solutions
Custody solutions can vary in complexity depending on the size of the exchange, the value of the assets under management, and the platform’s specific needs. Common custody solutions used by centralized exchanges include:
1. Cold Storage
In cold storage, all cryptocurrencies are stored offline and are not connected to the internet, minimizing the risk of hacking. The purpose and benefits of cold storage become clear when considering that hot wallets or any other form of online cryptocurrency storage carry inherent risks of external threats. Notably, cold wallets act as a dictionary on the network, and despite being offline, they allow transaction signing.
Hardware Wallets:
Hardware wallets are one of the most common forms of cold storage, where private keys are stored on a physical device. These wallets can sign offline transactions and only connect to the internet when a user wants to make a withdrawal or transaction.
Paper Wallets:
Some exchanges, particularly new ones, offer paper wallets. Simply put, a private key and an address are generated online and printed on a piece of paper. However, paper wallets do not protect against risks such as loss, unauthorized use, or other issues, especially for significant transactions.
Air-Gapped Computers:
More cautious exchanges go beyond the previously mentioned wallets by using air-gapped systems (computers with no internet, USB, or external connectivity, and data is exchanged only through specific protocols). This guarantees a higher level of security as private keys never connect to the network.
Cold storage is predominantly used for a significant portion of an exchange’s funds, particularly those not involved in daily trading. However, this approach has its drawbacks, including reduced activity and delays in withdrawals, as transferring funds from these wallets requires human intervention and strict security measures.
2. Hot Storage
Unlike cold storage, hot wallets are connected to the internet and are used for daily transactions on exchanges. These wallets provide the necessary liquidity for quick transaction processing, deposits, withdrawals, and trades.
While hot wallets are significantly convenient for both users and exchanges, they are also more susceptible to hacking. If an attacker successfully breaches an exchange’s systems, they could compromise hot wallets and steal funds. Therefore, exchanges are responsible for implementing adequate security measures for hot wallets, such as:
Multi-Signature Wallets:
These wallets require more than one party to sign off on a transaction, reducing the likelihood of unauthorized transfers, as an attacker would need multiple private keys to move funds.
Real-Time Monitoring:
Real-time monitoring systems are often employed to detect suspicious activities, such as unusually large or irregular withdrawals, allowing for prompt responses to potential threats. Hot wallets are integrated with automated alert systems that mitigate the risk of cyberattacks.
Most exchanges strive to keep minimal assets in hot wallets—only what is necessary for operational liquidity—while transferring the majority of user funds to cold storage. This hybrid storage model balances security and usability.
3. Multi-Party Computation (MPC)
Multi-party computation (MPC) is a more advanced cryptographic technique gaining traction in the custody and storage space. With MPC, private key fragments are distributed among multiple parties, ensuring that no single entity holds the complete key. The parties must collaborate to authorize a transaction without ever sharing their respective key fragments, thereby enhancing security.
The primary advantage of MPC is its ability to reduce the risk of a single point of failure. Even if one party’s key fragment is compromised, an attacker cannot transfer funds without the other fragments. This solution is particularly beneficial for exchanges seeking a more flexible alternative to cold storage while minimizing the risk of private key theft.
With MPC, asset management becomes more seamless, allowing exchanges to securely move funds without the delays typically associated with transferring from cold to hot storage. This makes MPC an appealing solution for exchanges aiming to maximize liquidity without compromising security, though it is not an inexpensive option.
4. Third-Party Custodians
With the exception of major centralized exchanges, many exchanges outsource custody to third-party custodians. These professional custodial companies specialize in safeguarding digital assets, often using cold storage solutions. They provide insurance for the assets they hold and ensure compliance with regulations, thereby increasing user trust. Well-known third-party custodians include Coinbase Custody, BitGo, and Anchorage.
Outsourcing custody to third parties allows exchanges to focus on their core operations, such as trading and liquidity management, while relying on experts for asset security. However, this approach introduces a layer of dependency, as the exchange must trust the custodian to protect user funds effectively.
Insurance and Risk Management
No custody or storage solution is complete without insurance to cover losses from theft, fraud, or operational failures. The fundamental principle of insurance is calculated and measurable risk. If a risk does not change over time or remains predictably consistent, insuring against it becomes feasible. For this reason, cold storage is often paired with robust insurance policies and innovative insurance methods, as it typically involves higher asset values. In contrast, hot storage insurance holds less value due to its higher and less predictable risks.
Challenges of Implementing Custody Solutions
Balancing Security and Accessibility: Cold vs. Hot

One major challenge is finding a balance between acceptable security and liquidity. Cold wallets, or offline storage, are highly secure but unfortunately impact an exchange’s ability to process timely withdrawals and transactions. Conversely, hot wallets, being online, are more vulnerable to hacks but are more practical for daily operations. Achieving a balance between sufficient accessibility and guaranteed security is a continuous challenge.
On the other hand, advanced custody techniques like MPC can help achieve this balance but require mature technology for implementation and specialized expertise for proper management. Small and medium-sized exchanges may lack the resources or expertise to deploy such solutions effectively.
Multi-signature wallets or third-party custodians also add operational complexity when managing multi-party access. Additionally, issues like wallet recovery or private key loss can pose significant challenges.
Auditing Solutions
As mentioned, trust is a crucial component in the crypto industry, particularly for centralized exchanges. Ensuring trust goes beyond security; it also involves aligning activities and transactions with domestic and international regulations. Consequently, auditing solutions have become a necessary practice for exchanges to demonstrate accountability, enhance transparency, and validate financial and operational integrity.
Auditing solutions refer to the processes and systems exchanges use to verify and validate reserves, security practices, and regulatory compliance. These audits can be conducted internally or by third-party auditors. In these processes, various aspects of an exchange’s operations, from financial capabilities to cybersecurity resilience, must be addressed.
Types of Audits in Cryptocurrency Exchanges

1. Financial Audits
Financial audits, especially in the form of Proof of Reserves, are among the most common auditing methods in centralized exchanges. As mentioned, these audits are designed and executed to confirm that an exchange holds sufficient assets to cover all user deposits. In other words, their goal is to prove that the exchange’s reserves (assets) exceed its liabilities (customer balances).
2. Security Audits and Inspections
Given the prevalence of hacks and cyberattacks in the crypto space, security audits are essential to ensure the robustness of exchange infrastructure. Security inspections evaluate the exchange’s ability to protect user funds from internal and external threats, identify potential vulnerabilities, and provide recommendations for improvement.
Security audits typically cover areas such as:
Cold and Hot Wallet Security:
Examining security measures surrounding cryptocurrency storage, including the use of cold storage for long-term asset protection and regularly updated multi-signature wallets for hot wallet transactions.
Private Key Management:
Ensuring private keys are securely stored and properly managed, particularly with advanced techniques.
Access Controls:
Reviewing how access to critical systems and funds is managed, ensuring only authorized personnel can conduct transactions or access sensitive information.
Incident Response:
Evaluating the exchange’s ability to detect and respond to breaches or security incidents in real time, including its preparedness to handle potential hacks or data leaks.
These audits are typically conducted by third-party cybersecurity firms specializing in blockchain technology. Audit results help exchanges identify weaknesses in their security protocols and take preventive measures to safeguard user funds.
3. Compliance Audits
As the regulatory landscape for cryptocurrencies continues to develop, centralized exchanges must adhere to an increasing number of laws and guidelines. Compliance audits are designed to ensure exchanges comply with relevant financial and legal regulations, particularly in areas like Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements.
Key components of compliance audits include:
KYC/AML Compliance:
Verifying that the exchange has appropriate systems to authenticate user identities, prevent illegal activities like money laundering, and comply with regional and international regulations.
Licensing and Legal Requirements:
Ensuring the exchange operates within the legal frameworks of the jurisdictions where it conducts business. This may include verifying the validity and currency of licenses or approvals required by financial and trade regulators.
Tax Compliance:
Ensuring the exchange meets its tax obligations and provides users with the necessary tools for tax reporting in their jurisdiction.
Data Privacy:
Reviewing data protection policies to ensure compliance with regulations such as the General Data Protection Regulation (GDPR) and consumer privacy laws.
Compliance audits are typically conducted regularly (in most countries by judicial and governmental bodies) to ensure continued adherence to regulations and demonstrate to regulators and users that the exchange operates within legal boundaries.
4. Operational Audits
Operational monitoring or audits focus on the exchange’s internal processes and controls to ensure they are efficient and effective. These audits assess whether the exchange has sufficient systems to manage risks, handle daily operations, and maintain the integrity of its trading platform.
Key areas covered in operational audits include:
Risk Management:
Evaluating the exchange’s ability to manage financial and operational risks, including market volatility, liquidity management, and contingency planning.
Internal Controls:
Assessing the effectiveness of internal controls, such as employee access to systems, fraud prevention mechanisms, and transaction monitoring.
Disaster Recovery:
Verifying that the exchange has adequate procedures for recovering from unexpected incidents or risks, including backup systems and protocols for dealing with outages or failures.
Operational audits help exchanges optimize their internal processes, reduce inefficiencies, and ensure smooth, reliable operations even under stressful circumstances.
Technologies and Methods in Auditing
Auditing in the cryptocurrency industry often employs advanced technologies to ensure transparency, accuracy, and security. Common methods and tools include:
Merkle Tree Audits:
As part of Proof of Reserves, exchanges use Merkle Trees to allow users to verify their balances without revealing other users’ data. The accuracy, functionality, and validity of this tree structure must always be verified.
Blockchain Analysis:
Auditors use blockchain analysis tools to trace and verify on-chain activities of the exchange. These tools provide real-time insights into fund flows and help identify any suspicious activity or anomalies.
Smart Contracts:
In some cases, exchanges rely on smart contracts to automate and validate specific processes, such as asset transfers or compliance checks. Smart contracts ensure that certain conditions are met before transactions are executed, adding an additional layer of accountability.
Automated Monitoring Systems:
Real-time monitoring systems are often used to detect unusual activities, such as large or suspicious withdrawals, hacking attempts, or operational errors. These systems can generate alerts for further investigation by auditors or internal teams.
These technologies enable exchanges to execute audit processes that are not only secure but also transparent, allowing for continuous oversight and verification.
Challenges in Implementing Audit Solutions
1. Cost of Auditing
Regular financial audits, third-party monitoring, security inspections, and compliance audits can be expensive, especially when conducted by reputable auditing firms. Continuous or real-time auditing requires significant financial and operational resources. For smaller exchanges, these costs can be prohibitive, potentially leading to incomplete or delayed audits.
2. Time Gaps Between Audits
Traditional audits are often conducted periodically (e.g., annually or semi-annually), leaving significant gaps in oversight. During these periods, the exchange’s financial or security status can change dramatically, leaving users vulnerable. This is particularly concerning in the fast-paced crypto markets, where liquidity can experience major fluctuations.
3. Auditor Independence and Integrity
Auditors must be independent and trustworthy for the process to be credible and reassuring. If an auditor has close ties to the exchange or is suspected of conflicts of interest, reports may be biased or overlook red flags. Trust in the auditor’s integrity is essential, but ensuring complete independence can be challenging, especially in smaller or less regulated markets.
4. Regulatory Uncertainty
Crypto regulations are still evolving, and exchanges often operate in multiple jurisdictions with differing legal frameworks and standards. Ensuring compliance with all relevant AML and KYC regulations is a major challenge, especially when regulations conflict. Regular compliance audits require exchanges to stay up-to-date with changing laws, which can strain resources and disrupt operations, particularly when practices vary significantly across regions.
5. Trust and Awareness
While audits are designed to inspire greater confidence, users may not fully understand the scope of an audit or what it covers. For example, a financial audit might confirm that an exchange has sufficient reserves but not verify its cybersecurity measures, even if they are promptly addressable. Such situations can create significant trust gaps among users, leading them to believe that either the audit is incomplete or that the exchange is hiding something. Effectively communicating audit results requires a high level of transparency and honesty to avoid unnecessary concern or misplaced optimism.
Conclusion
While Proof of Reserves, custodial solutions, and audit mechanisms are critical components for centralized exchanges to build trust and protect user assets, implementing them comes with significant challenges. These challenges span a wide range of factors, from technical barriers to regulatory complexities. For now, it seems there is no alternative but for centralized exchanges to navigate these complexities to maintain security and transparency. As the cryptocurrency industry continues to evolve, centralized exchanges must consistently improve these methods and systems to remain secure, transparent, and trusted by users. This requires not only overcoming existing challenges but also adapting to the technological and regulatory landscape.
Finally, it’s worth noting that while centralized exchanges currently benefit from these solutions individually, they often approach them in a fragmented manner. A holistic integration of these components could become a cornerstone for these exchanges, ensuring their credibility and user confidence.