SACF-04 — Ownership & Evidence: how can a company prove that it actually holds its stablecoins?
Updated: Aug 29
RESEARCH & INTELLIGENCE • SACF 2026
BECTRA SACF — Stablecoin Accounting & Control Framework • Pillar 4 of 7 • Ownership & Evidence
01 Classification → 02 Purpose & Exposure → 03 Accounting & Measurement → 04 Ownership & Evidence → 05 Counterparty & Infrastructure → 06 Governance & Control → 07 Reconciliation & Reporting
How can the company prove that it actually owns the stablecoin?
Seeing a balance in an application or on a blockchain does not, by itself, establish that the company legally owns and effectively controls the stablecoins. SACF-04 organises the evidence chain linking the legal entity, wallet or account, access rights and observable position.
SACF CONNECTION — Proving ownership also requires evidence of who can access wallets, approve transactions and exercise control powers. SACF-06 explores this point in greater detail.
SACF PRINCIPLE — Ownership must be identifiable, controlled and provable.
1. Identify the custody model
SACF CONNECTION — Ownership evidence also depends on the counterparties and infrastructures that hold, record or provide access to the position. SACF-05 explores this point in greater detail.
Self-custody, corporate wallets, MPC, multisignature, provider accounts and omnibus structures create different evidence chains. The file should describe who holds keys, who can sign, how rights are delegated and how client assets are segregated.
2. Link the legal entity to the wallet or account
For each material position, the company should be able to connect the address, account or sub-account to the relevant legal entity. The file should specify network, token, contract where relevant, any provider involved and how control over the position is exercised.
3. Prove control without exposing secrets
Evidence of control never means disclosing a private key or seed phrase. It may rely on message signing, a test transaction, entitlement registers, provider attestations, MPC or multisig configuration evidence, and internal documentation linking authorised signers to the company.
SACF RULE — Prove control without ever disclosing the secret element that enables it.
4. Build an on-chain and off-chain evidence chain
On-chain data evidences positions and movements. Off-chain documentation evidences attribution to the company: contracts, statements, procedures, signer registers, wallet-opening decisions, transfer support and custody attestations. Both dimensions should converge.
5. Address complex cases
Bridged tokens, exchange balances, omnibus wallets, smart-contract positions, delegated signing, frozen assets and MPC arrangements require additional evidence. A balance is not enough if the company cannot demonstrate its right to access, dispose of or recover the assets.
6. Produce dated and reproducible period-end evidence
The period-end file should retain a dated position statement, the method used to attribute wallets or accounts to the company, evidence of control, custody statements and any exceptions. A third party should be able to understand who controls what, at what date and on what documentary basis.
SACF CONNECTION — SACF-03 determines how the position is accounted for. SACF-04 demonstrates that it belongs to the company. SACF-07 later uses that ownership perimeter to reconcile positions with accounting.
Sources
Continue through the BECTRA SACF framework
To extend this analysis, the following pillars are the most directly connected to the issues addressed in this article.
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