Custody Chain Notes Trustees Should Keep on Paper

A trustee who knows where every hardware wallet is stored today may not be the trustee who needs that information in five years. Custody chain documentation survives personnel changes because it lives outside the devices it describes.

What to record

Device identification — Manufacturer, model, and serial number if available. Not the recovery phrase.

Physical location — Office room, safe identifier, off-site facility name. Update when location changes.

Signatory roles — Who can authorize transfers, who holds backup materials, who witnessed last verification.

Backup arrangements — Where duplicate materials are stored, who has access, rotation schedule if applicable.

What never belongs in reserve logs

Recovery phrases, private keys, PIN codes, and biometric access details must not appear in documentation intended for accountant review or committee distribution. If your current records include these, segregate them before any external review.

Amendment practice

When a signatory departs or a device relocates, add an amendment page rather than editing the original entry. Auditors reading a five-year archive need to see the chain of custody changes, not a single corrected line.

Field verification

Our on-site sessions focus on confirming that recorded locations match physical reality. Discrepancies are noted in the verification log before binding. Quarterly Refresh engagements update amendment pages after changes.