This publication was updated on July 28, 2022, to reflect recent discussions the AICPA Digital Assets Working Group has had with the SEC staff as well as updated Q&As in the AICPA Practice Aid Accounting for and Auditing of Digital Assets (the “AICPA Practice Aid”).
SEC Staff Accounting Bulletin Topic 5.FF, “Miscellaneous Accounting; Accounting for Obligations to Safeguard Crypto-Assets an Entity Holds for Its Platform Users.”
This list is not all-inclusive; not all of these risks need to be present for a safeguarding obligation to exist. For more information, see Question 2 in Appendix B of the AICPA Practice Aid.
See Question 3 in Appendix B of the AICPA Practice Aid.
See Question 7 in Appendix B of the AICPA Practice Aid.
See Question 6 in Appendix B of the AICPA Practice Aid.
See Question 9 in Appendix B of the AICPA Practice Aid.
For titles of FASB Accounting Standards Codification (ASC) references, see Deloitte’s “Titles of Topics and Subtopics in the FASB Accounting Standards Codification.”
IFRS 13, Fair Value Measurement.
IFRS 3, Business Combinations.
See Question 8 in Appendix B of the AICPA Practice Aid.
See Question 10 in the AICPA Practice Aid.
An entity should first determine whether it has control over the crypto-assets. If so, SAB 121 does not apply. See Question 4 in Appendix B of the AICPA Practice Aid.
Crypto-assets, as defined in Question 1 of AICPA Practice Aid Accounting for and Auditing of Digital Assets, are accounted for as intangible assets. Note that SAB 121 refers to crypto-assets more broadly than the definition used in Question 1 of the AICPA Practice Aid. See the Scope Considerations section for additional discussion.
IAS 1, Presentation of Financial Statements.
See Questions 16–21 in the AICPA Practice Aid.
SEC Regulation S-K, Item 101, “Description of Business.”
SEC Regulation S-K, Item 105, “Risk Factors.”
SEC Regulation S-K, Item 303, “Management’s Discussion and Analysis of Financial Condition and Results of Operations.”
SEC Regulation A, Rule 257(b), “Tier 2: Periodic and Current Reporting.”
SEC Staff Accounting Bulletin Topic 11.M (SAB 74), “Miscellaneous Disclosure; Disclosure of the Impact That Recently Issued Accounting Standards Will Have on the Financial Statements of the Registrant When Adopted in a Future Period.”
IAS 8, Accounting Policies, Changes in Accounting Estimates and Errors.