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Internal Audit for the on-chain era

Digital assets are moving deeper into institutional banking, reshaping where risks sit and how they appear. Explore how Internal Audit can evolve its coverage, controls and capabilities for the on-chain era.

Digital assets in banking: Internal Audit for the on-chain era | KPMG

Prepare Internal Audit for the on-chain era

Explore the risks, controls and audit considerations shaping digital assets in banking.

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KPMG Digital Assets Advisory services
Amid accelerating regulatory developments, increased support from policymakers, and growing market activity, digital asset adoption is reaching a tipping point.

The window to prepare is closing

Stablecoins, tokenized deposits, on-chain payments and custody are changing banking infrastructure and the operational, compliance and risk considerations that come with it.

As regulatory frameworks evolve and adoption expands, Internal Audit should understand how digital assets affect the risk universe, existing controls and audit coverage.

“Digital assets don’t replace the risks banks already know, they change where those risks sit and how they show up.”

Paul Heidler

Managing Director Internal Audit & Controls Digital Asset Leader, KPMG LLP

Where should Internal Audit focus?

The impact on Internal Audit depends on the digital asset use cases an institution adopts and their associated risk profiles. The report examines six key areas:

Stablecoin issuance

Payments and settlement

Tokenized deposits and interbank clearing

Custody

Trading and brokerage

Tokenization of real-world assets

Following the digital asset payment lifecycle

Digital asset payments introduce control considerations across the transaction lifecycle, from customer onboarding through on-chain execution, reconciliation and payout.

Lifecycle graphic

New infrastructure. New risk considerations.

On-chain activity changes several assumptions embedded in traditional banking controls. Internal Audit should consider risks related to transaction finality, wallet and key management, continuous operations, financial crimes, third-party dependencies and internal skillsets.

Cross-cutting areas include:

1

Cybersecurity and key management

2

Disaster recovery and resiliency

3

Data governance and lineage

4

Model risk and pricing

5

Third-party risk management

6

Financial crime compliance

Callout Outsourcing does not transfer accountability. Banks remain accountable for digital asset activities performed by third parties.

A four-step blueprint for modernization

Internal Audit leaders can consider four actions as they prepare for digital asset operations:

01
Determine how digital assets impact the audit universe

Map activities across products, entities, technology platforms, third parties and shared networks.

02
Perform targeted risk assessments

Assess risks by use case and lifecycle stage, including third-party and on-chain dependencies.

03
Refresh control testing and capability

Build technical fluency and enhance testing capabilities for emerging digital asset risks.

04
Deploy a prioritized coverage strategy

Align audit coverage with the institution’s planned and implemented digital asset use cases.

How KPMG can help

KPMG combines banking knowledge with digital asset specialists to help Internal Audit functions address emerging risks, coverage needs and capability gaps.

Areas of support

  • Enterprise and audit risk assessment
  • Co-source and loan-staff support
  • Audit scoping and plan design
  • Digital asset audit outsourcing
  • Vendor, custodian and consortia audits
  • Regulatory readiness and exam support
  • Specialized digital asset support

Prepare Internal Audit for the on-chain era

Explore the risks, controls and audit considerations shaping digital assets in banking.

The Future of Internal Audit

Manage disruption while building stakeholder trust

Meet the team

Image of Brian Consolvo
Brian Consolvo
Principal, Cyber and Technology Risk, KPMG LLP
Image of Paul R Heidler
Paul R Heidler
Managing Director, Assurance, KPMG US

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