
Bitcoin Treasury Governance Checklist for the Audit Committee
A 24-point pre-allocation governance checklist covering mandate, custody, accounting, stress response, disclosure, and reporting cadence.
Use this as a pre-allocation gate. If any item is unchecked, the Strategy is not ready for board ratification — regardless of how compelling the macro thesis sounds in the room.
Mandate and authority
- Written investment policy explicitly authorizes long-duration alternative assets
- Upper allocation bound defined as a % of unrestricted reserves, not total cash
- Audit Committee charter updated to include digital-asset oversight
- Delegation of authority memo signed by the CFO and Board Chair
Custody and controls
- Qualified custodian selected with current SOC-2 Type II report on file
- Multi-signature scheme documented with named signers and quorum rules
- Segregation of duties matrix mapped to the existing financial-control framework
- Insurance certificate reviewed by risk and legal
Accounting and tax
- Fair-value methodology under FASB ASU 2023-08 documented by the Controller
- Draft footnote disclosure reviewed by external auditor
- Tax treatment confirmed in writing by the Company's tax advisor
- ERP and sub-ledger configured to capture fair-value movements per period
Stress response
- Drawdown bands and pre-authorized actions defined under SRF
- Emergency authority matrix circulated to named officers
- Communications template drafted for material drawdown events
- Tabletop exercise scheduled within 90 days of first allocation
Disclosure and IR
- Earnings-call talking points and investor Q&A drafted
- Regulation FD review completed by securities counsel
- Press-release template approved by IR and legal
- Internal employee-communication memo prepared
Reporting cadence
- Quarterly Audit Committee dashboard template approved
- Annual full-Board review scheduled on the governance calendar
- Breach-event escalation path tested end-to-end
- Control-testing plan included in the internal-audit annual plan
A 24-of-24 score does not guarantee a good outcome. A 22-of-24 score guarantees a governance failure under stress.
Continue the playbook
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