robinhood
ROBINHOOD CRYPTO, LLC
•
REGULATORY & CUSTODY
ARCHITECTURE
POLICY MEMORANDUM
Digital
Asset
Governance
&
Trading
Compliance
TO:
Engineering, Product Operations, Global Compliance, Risk Management & Legal
FROM:
Vlad Tenev, CEO & General Manager, Robinhood Crypto
DATE:
September 21, 2026
SUBJECT:
Robinhood Cryptocurrency Policy: Asset Listing Standards, Cold Custody & Global
Compliance
1. PURPOSE & STRATEGIC VISION
Robinhood's mission to democratize
fi
nance extends directly to digital currencies and decentralized protocols. As
retail investors and global markets transition toward 24/7 on-chain liquidity, Robinhood Crypto provides intuitive, cost-
e
ffi
cient, and secure access to digital assets while maintaining industry-leading consumer protections and strict
regulatory alignment.
This policy memorandum codi
fi
es the operational rules, technical architecture, and risk baselines governing
Robinhood Crypto, LLC and our expanding European international operations. It formalizes our asset-listing criteria,
enforces cold-storage multi-sig custody mandates, establishes anti-fraud transaction monitoring, and details
customer self-custody transfer safeguards.
2. FOUR CORE PILLARS OF CRYPTOCURRENCY OPERATIONS
Every product rollout, liquidity partnership, and blockchain integration must adhere to four operational pillars:
Conservative, Rules-Based Asset Listings:
Prioritizing legal and regulatory clarity above speculative volume.
Assets considered for listing undergo rigorous statutory scrutiny under federal securities frameworks (Howey
analysis), technical smart contract audits, and liquidity risk assessments.
Air-Gapped Institutional Cold Storage:
The overwhelming majority of customer crypto assets are held in
geographically dispersed cold storage systems with hardware security modules (HSMs), multi-party computation
(MPC), and air-gapped signing ceremonies.
Zero Balance Sheet Rehypothecation:
Customer cryptocurrency is held strictly 1:1 in segregated custody.
Robinhood does not lend, stake, hypothecate, or speculate with customer assets without explicit, legally
documented opt-in programs.
Unfettered Bi-Directional Web3 Portability:
Supporting seamless on-chain deposits and withdrawals across
supported layer-1 and layer-2 blockchains, ensuring customers retain the freedom to move assets to self-custody
wallets without punitive exit hurdles.
Custody Standard:
Assets deposited with Robinhood Crypto are property of the customer. We maintain complete
balance isolation between corporate operational treasury and retail custodial holdings. Every Satoshi, Gwei, and token
unit is auditable on-chain and backed 1:1.
3. ON-CHAIN TRAVEL RULE & ADDRESS SCREENING
To comply with FinCEN guidelines and the FATF Travel Rule, all incoming and outgoing crypto transfers undergo
automated screening via Elliptic and Chainalysis heuristics to identify interactions with sanctioned protocols, mixers,
darknet entities, or stolen treasury wallets prior to mempool broadcasting.
Robinhood Markets, Inc.
—
Con
fi
dential Internal Policy Directive
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