Crypto Custodian Passes OJK Sandbox: How Is It Different from an Exchange?

Indonesia’s Financial Services Authority, or OJK, announced that PT Tennet Depository Indonesia passed the regulatory sandbox on June 11, 2026. Its tested business model was a non-trading digital financial asset custodian under the product name Tennet.

The result moves the custody model closer to Indonesia’s formal digital-finance framework. It does not automatically constitute a full operating licence or guarantee that assets held by the service cannot be lost.

A regulatory sandbox tests a business model, its technology, governance, risks, and consumer-protection arrangements before the model proceeds to registration or licensing. A participant that passes still needs to complete the follow-up process required by OJK.

It is also necessary to separate the role of a custodian from that of an exchange. Both may be involved in safeguarding assets, but they do not perform the same function.

PT Tennet Depository Indonesia passed OJK’s regulatory sandbox with a non-trading digital financial asset custody model. Source: Indonesia Financial Services Authority, June 2026 Board of Commissioners meeting release published on July 7, 2026. Sandbox graduation is not automatically equivalent to a full operating licence.

What Is a Non-Trading Crypto Custodian?

A crypto custodian safeguards and administers digital assets or the cryptographic access used to control them. Its main role is not to match buyers and sellers. It is to ensure that assets can be held, recorded, transferred, and returned under authorized instructions.

The non-trading label indicates that custody is separated from buying and selling. The custodian does not need to operate an order book or provide trading pairs.

This structure may be useful for institutional investors, RWA issuers, crypto fund managers, or companies that need asset storage without assigning trading and custody to the same entity.

The word custodian does not automatically mean that all assets are held in cold storage or fully covered by insurance. The wallet architecture, asset-segregation policy, legal liability, and insurance scope still need to be reviewed.

Custodians, Exchanges, and Self-Custody

The comparison is conceptual. A company may hold several authorizations or use a separate custody provider.

How Exchange Custody Usually Works

When a user deposits Bitcoin into a centralized exchange, the blockchain records a transfer to an address controlled by the platform or its custodian. After enough confirmations, the exchange credits the user’s internal balance.

Later trades do not normally move Bitcoin on-chain each time. The exchange updates balances in its internal ledger. Another blockchain transaction usually occurs when assets are withdrawn, transferred between wallets, or settled externally.

This allows trading to take place quickly without paying a network fee for every internal ownership change. It also means the user depends on the exchange to:

• protect private keys;

• maintain accurate account records;

• segregate customer assets;

• preserve withdrawal liquidity;

• secure its systems;

• process authorized transfers.

How Separate Custody Can Work

Under a separate custody model, the trading platform or fund manager does not need to control all private keys. The custodian holds the assets, while another entity manages trading instructions or investment decisions.

A simplified process may look like this:

1. Assets are deposited into an address managed by the custodian.

2. The custodian confirms the deposit on-chain.

3. The customer’s entitlement is recorded.

4. A trading platform receives confirmation that the assets are available.

5. Trades change economic entitlements in an internal ledger.

6. The custodian transfers assets only after receiving a valid instruction.

Separating custody from trading may reduce concentration of functions. It also creates more operational dependencies. The trading platform, custodian, blockchain network, reconciliation system, and authorization controls must work together.

Protecting Private Keys

OJK’s public announcement does not disclose Tennet’s detailed wallet architecture. It would therefore be inaccurate to claim that the company uses a particular custody method without additional documentation.

Digital-asset custodians generally use combinations of:

• cold storage for assets that do not need immediate movement;

• hot wallets for operational transfers;

• multi-signature controls requiring several keys;

• multi-party computation that divides signing capability across several systems;

• policy engines that apply value limits, approved addresses, waiting periods, and layered approvals.

Technology alone is not enough. A custodian also needs access controls, separation of duties, monitoring, backup, incident response, and recovery procedures.

Passing the Sandbox Is Not the Same as Receiving a Full Licence

Under OJK Regulation Number 3 of 2024, a sandbox test generally lasts no longer than one year from approval unless OJK sets a different period.

A participant may receive a passed or failed outcome. A successful participant then follows the registration or business-licensing route determined by OJK.

Participants that pass the sandbox must still follow the registration or business-licensing process required by OJK. Source: Indonesia Financial Services Authority, Regulatory Sandbox page under OJK Regulation Number 3 of 2024. A passed result should not be presented as a full operating licence.

The stages should be described separately:

• Sandbox participant: the model is being tested.

• Passed sandbox: testing has been completed with a successful outcome.

• Registered: the registration process has been completed.

• Licensed: the entity has received authorization to conduct activities within the approved scope.

The current status should be checked through OJK’s licensing records, not inferred only from a sandbox announcement.

Why Separate Custody May Matter

Separate custody can reduce the number of functions controlled by one company. It may also support institutional requirements for transaction authorization, asset reporting, audit trails, and independent recordkeeping.

The model can be relevant to RWA issuers and crypto fund managers that need a specialized party to hold digital assets.

Its usefulness depends on clear legal agreements and accurate reconciliation. If the custodian and trading platform maintain inconsistent records, separating the companies does not prevent a dispute.

Risks That Still Remain

Legal Segregation

Customers need to know whether their assets are legally segregated from the custodian’s own assets. This becomes critical if the custodian enters insolvency proceedings.

Omnibus Wallets

A custodian may combine assets belonging to many customers in shared wallets. This is efficient, but the internal ledger must accurately record each customer’s entitlement.

Operational Failure

Incorrect addresses, unauthorized approvals, failed backups, or system outages can delay or permanently affect access to assets.

Third-Party Dependencies

Cloud providers, MPC vendors, auditors, insurance companies, and blockchain networks may all support the service. Failures outside the custodian can still disrupt operations.

Withdrawal Restrictions

Users need to understand processing times, transaction limits, security delays, and the circumstances under which withdrawals may be paused.

Insurance Limitations

Insurance may contain coverage limits, exclusions, deductibles, and conditions. A statement that assets are insured does not prove that every loss will be reimbursed.

Proof of Reserves Is Not a Custody Audit

Proof of Reserves can show whether disclosed assets cover user balances included in a snapshot. It does not necessarily reveal every liability, private-key control, legal segregation arrangement, or operational weakness.

MEXC provides a Proof of Reserves page through which users can review reserve coverage for several major assets. That information can support a transparency assessment, but it should not be treated as the only measure of platform safety.

Custody raises additional questions:

• Who controls the private keys?

• Are customer assets legally segregated?

• How are withdrawals approved?

• How are balances reconciled?

• What happens during a system outage?

• Who absorbs an operational loss?

Proof of Reserves, financial audits, technology audits, and regulatory supervision address different parts of the risk.

What OJK’s Announcement Does Not Yet Show

The sandbox announcement confirms Tennet’s company name, product name, business model, and graduation date. It does not provide detailed public information on:

• supported assets;

• target customers;

• supported blockchains;

• hot- and cold-wallet architecture;

• multi-signature or MPC controls;

• legal segregation of customer assets;

• insurance;

• withdrawal procedures;

• independent audits;

• current full licensing status.

The absence of these details does not prove that controls are weak. It means the sandbox announcement alone is not enough to evaluate the service.

What Should Be Monitored Next?

The next stage is to see how the non-trading custody model becomes a licensed and supervised service.

Relevant developments include:

• Tennet’s registration or licensing status;

• the approved custody scope;

• capital and governance requirements;

• customer-asset segregation standards;

• audit and reporting obligations;

• rules for third-party technology providers;

• lost-key and incident-response procedures;

• withdrawal and operational-recovery standards;

• relationships with exchanges, RWA issuers, and crypto fund managers.

Passing the sandbox confirms that the model completed a regulatory testing process. Its practical value will depend on implementation, transparency, and the protections available when a real failure occurs.

A custodian can reduce the user’s private-key burden. It does not eliminate risk. It transfers part of that responsibility to an institution that must have adequate technology, procedures, capital, and governance.

Disclaimer

This article is provided for information and education only. It is not a recommendation to use any specific custody provider. Passing a regulatory sandbox does not automatically constitute a full operating licence, government guarantee, or guarantee against losses. Licensing status and service terms may change. Users should verify current information through OJK and the provider’s official documents.