US SEC Issues SAB 121: Accounting for Custody of Crypto-Assets

On March 31, 2022, the US Securities and Exchange Commission (the “SEC”) published Staff Accounting Bulletin No. 121 (the “Bulletin”), expressing the views of the staff in the Division of Corporation Finance and the Office of the Chief Accountant regarding the accounting of, and associated disclosures relating to, an entity’s obligation to safeguard crypto-assets an entity holds for platform users. This Legal Update focuses on who is affected, what the affected entities need to do and when the guidance applies; summarizes Commissioner Hester M. Peirce’s response to the Bulletin; and discusses some practical considerations for affected entities.

Additional Authors: Kimberly Ayudant and Marc X.W. Leong.