Choose the Product Model Before the Technology
“Crypto broker” can describe several different businesses: cash-settled CFDs, spot exchange execution, agency routing, wallets, custody or payment services. These models create different licensing, safeguarding, market-abuse, financial-promotion, reporting and operational duties. The entity and legal perimeter must therefore be decided before selecting symbols or integrations.
Crypto CFDs
Cash-settled price exposure. Confirm client eligibility, leverage, disclosures, hedging and counterparty arrangements.
Spot or agency
Orders may route to an exchange or venue. Confirm execution, settlement, asset ownership and venue due diligence.
Wallet and custody
Define who controls keys, segregates assets, approves transfers and carries loss or recovery obligations.
Payments
Fiat and crypto funding need separate provider approvals, transaction monitoring, wallet screening and reconciliation.
Instrument and Contract Scope
Symbols such as BTC/USD or ETH/USD are common evaluation examples, not a statement of live availability. The broker should approve a versioned symbol schedule from the contracted provider. It should record the underlying reference, quote currency, trading hours, contract size, order limits, margin, financing, corporate-action policy and suspension process.
Adding a token name to a platform is not enough. Legal review should address whether the product is permitted, whether a token has special treatment, which clients may access it and how marketing describes the exposure.
Price Formation, Liquidity and Execution
Crypto pricing can differ materially between venues. The design should identify the source or sources, aggregation method, stale-price threshold, outlier rule, weekend coverage and contingency feed. If orders route externally, test each route’s depth, minimum size, rejects, slippage, fees and settlement mechanics.
- Normal conditions: verify spreads, depth, fills and reconciliation for expected order sizes.
- Stressed conditions: test gaps, rapid moves, thin depth, disconnects and abnormal-price controls.
- Operations: record price overrides, symbol suspensions, incident decisions and client communications.
- Evidence: use measured route percentiles and fill outcomes; avoid untested latency or liquidity promises.
Custody, Wallets and Payment Boundaries
A trading platform connection does not automatically include exchange membership, a wallet, custody, safeguarding or a payment account. Every asset and money flow should show the legal entity, provider, account owner, approval step, ledger entry and reconciliation owner. Where private keys exist, the scope should also address key generation, access, backup, transaction approval and recovery.
Contract boundary: provider onboarding, banking, payment acceptance, custody and regulatory approval remain subject to each provider’s underwriting and the broker’s permissions. Technology delivery does not guarantee any approval.
Broker Risk and Compliance Controls
Client controls
Eligibility, appropriateness, KYC, sanctions, geographic restrictions, risk warnings and account limits.
Market controls
Price bands, stale-feed rules, order limits, margin, liquidation, exposure limits and emergency suspension.
Financial-crime controls
Source-of-funds checks, wallet screening where applicable, transaction monitoring and case escalation.
Operational controls
Access control, four-eyes changes, audit logs, daily reconciliation, incident handling and data retention.
Evidence-Based Launch Checklist
- Approve the entity, jurisdictions, client types and precise product model.
- Complete due diligence and contracts for platform, pricing, execution, custody and payments.
- Approve each symbol, contract specification, risk limit and client disclosure.
- Test normal, stressed and recovery scenarios on the intended production route.
- Reconcile balances and positions, close material defects and record accountable sign-off.
Frequently Asked Questions
A cash-settled CFD can provide price exposure without delivering the underlying asset, but the permitted product, client type, marketing and leverage depend on the broker’s jurisdiction and permissions. The legal perimeter must be confirmed before configuration or promotion.
Instrument availability is limited to the broker’s legal permissions and the contracted provider’s current symbol schedule. Each symbol requires an approved price source, trading schedule, contract specification, margin rule and fallback procedure.
Not automatically. CFD pricing, spot exchange connectivity, wallet infrastructure, custody and payment processing are separate functions. The written scope must name which functions are provided, by whom, and which entity controls client assets or private keys.
Underlying venues may operate continuously, but a broker’s product can have maintenance windows, close-only periods, provider outages or jurisdictional restrictions. The approved symbol schedule and incident procedure govern actual availability.
Test price freshness, spreads, depth, order-size limits, rejects, slippage, disconnects, weekend conditions, abnormal moves, liquidation logic, reconciliation and recovery on the intended production route. Data-centre proximity alone is not execution evidence.
