Summary: DAOs can manage treasury funds with strong compliance oversight today by combining qualified custody platforms (with built‑in policy engines and Travel Rule tooling), on‑chain smart‑account controls (Safe modules, roles, spending limits), and a KYT/Travel Rule stack (TRM/Chainalysis/Notabene/Circle). Below is a concrete, vendor‑specific playbook with legal wrapper options (Wyoming DUNA, Utah LLD, RMI DAO LLC) and implementation steps you can execute in 30/60/90 days.

Where Can DAOs Manage Treasury Funds with Compliance Oversight?

Decision‑makers now have credible, production‑grade ways to run DAO treasuries under institutional controls without giving up on decentralization. The winning pattern is a hybrid:

Wrap the on‑chain DAO in an entity when needed (for liability, banking, tax).
Use qualified custody or non‑custodial smart accounts with enforceable policy engines.
Screen counterparties and flows with Travel Rule + KYT controls before settlement.
Keep audit‑ready books with a crypto subledger integrated to your ERP.

Below we map the concrete options, what they actually do in 2025, and how to assemble them.

The regulatory baseline you must design for (2024–2026)

EU: MiCA stablecoin rules went live June 30, 2024; full CASP requirements and the EU Transfer of Funds “Travel Rule” obligations have applied since December 30, 2024, with member‑state transitional windows running as late as July 1, 2026. ESMA/EBA have issued the first technical standards and Travel Rule guidelines setting out what information must accompany crypto transfers and how CASPs handle incomplete data. (esma.europa.eu)
U.S.: Enforcement risk is real for DAOs that offer financial products without registration (e.g., BarnBridge settlement, Dec 23, 2023). Design for “entity + controls,” not “pure code is law.” (jdsupra.com)

Option 1: Qualified custody with policy engines (maximum institutional oversight)

If you need segregation of duties, audit trails, Travel Rule workflows, and on‑chain governance participation—without hot‑wallet risk—use a qualified custodian with a policy engine and built‑in AML tooling.

Anchorage Digital (federally chartered crypto bank)
- Governance from custody: participate in Snapshot and supported on‑chain votes with quorum‑based internal approvals; supports governance for protocols such as Aave and Maker without moving assets from custody. (anchorage.com)
- Institutional staking and reporting from qualified custody. (stake-anchorage.com)
- Independent SOC attestation history; bank‑grade controls over key custody. (anchorage.com)
Coinbase Prime (custody + brokerage + policy engine)
- Consensus policies at entity/portfolio/transfer level; granular transfer controls by type, destination allowlist, asset, amount bands, plus optional video verification for high‑risk moves. (help.coinbase.com)
- On‑chain wallet policy engine lets you codify approver counts per condition (e.g., “≥2 approvers for withdrawals >$500k to external addresses”). (help.coinbase.com)
- Prime and Custody have completed SOC reports; staking SOC2 Type 1 added in 2025 (Deloitte). (coinbase.com)
BitGo (global trust entities)
- Wallet‑level policy engine and programmatic address allowlists/denylists; Travel Rule obligations apply for transfers from BitGo’s regulated entities (EU, MENA, Singapore). (developers.bitgo.com)
Fireblocks (institutional MPC with embedded compliance)
- Native KYT/AML integrations (Chainalysis/Elliptic) and a Notabene Travel Rule integration wired directly into the transaction flow, so compliance decisions are tied to settlement; recent encrypted PII messaging for Binance‑specific Travel Rule requirements. (fireblocks.com)

Why this matters: custodial policy engines give you “approve/deny/route” logic (who, how much, where, when) and comprehensive logs for SOC/ISO auditors—while Travel Rule checks run before assets move.

Option 2: Non‑custodial smart accounts with on‑chain controls (trust‑minimized, compliance‑enforced)

For DAOs that prefer to self‑custody treasuries (and still want enforceable guardrails), use Safe smart accounts with modules and roles:

Safe spending limits (Allowance module)
- Set “100 USDC/day” or “one‑time 50,000 USDC” allowances per beneficiary; transfers under the limit execute without collecting all multisig signatures—ideal for ops or AI agents with strict caps. (help.safe.global)
- Safe’s official quickstart shows configuring an AI agent as a beneficiary within explicit token/time limits. (docs.safe.global)
Zodiac Roles Modifier (granular role‑based permissions)
- Create roles that can only call specific functions on specific contracts with parameter bounds and rate/threshold limits (e.g., “Treasury‑Ops may swap up to 25,000 USDC/week on a whitelisted DEX”). SDK and app provided. (docs.roles.gnosisguild.org)
SafeSnap / Zodiac Reality Module (binding votes)
- Bridge off‑chain Snapshot results on‑chain for execution by the Safe after cooldown/bond conditions—turning community votes into enforceable transactions without relying on signers. (zodiac.wiki)
Session keys for automation (AA)
- With account‑abstraction wallets, scope “session keys” by time, function allowlists, and ERC‑20/native spend caps—good for bots/agents executing repetitive tasks under hard limits. (alchemy.com)

Practical guardrail pattern (non‑custodial):

Treasury Safe (e.g., 3/5 or 4/7) owns funds.
Install Spending Limits for small recurring ops; add Zodiac Roles for function‑scoped permissions to specific DeFi contracts; route all agent activity through session keys with expiry and spend caps.
Add a “circuit‑breaker” role (pause/disable modules) controlled by a higher‑threshold Safe.

Your compliance stack: screen counterparties, satisfy Travel Rule, keep an audit trail

KYT/AML screening
- Chainalysis KYT provides real‑time transaction risk scoring across 400+ networks and 50M+ tokens; alerts on direct and indirect exposure to sanctioned entities; API integration for automated pre‑transaction checks. (chainalysis.com)
- TRM Labs Wallet Screening API offers sub‑300ms risk scoring, VASP attribution, and expanded indirect exposure across 36+ chains—usable in front of payments or dApp access control. (trmlabs.com)
Travel Rule interoperability
- Notabene ties pre‑transaction authorization to settlement, supports multi‑protocol reachability (SafeGateway), and integrates natively with Fireblocks; guidance emphasizes screening originator/beneficiary and halting transfers before they settle if risk is detected. (notabene.id)
- Industry progress: nearly all VASPs expect to be fully Travel Rule‑compliant by 2025; an increasing share block withdrawals until beneficiary info is confirmed. (coindesk.com)
Circle’s Compliance Engine (for app‑embedded wallets)
- Address screening, allowlists/blocklists, Travel Rule (EA), and reporting consolidated with wallet operations—useful if your DAO ecosystem app issues wallets to contributors or vendors. (circle.com)

How DAOs use this in practice:

Custodial route: configure KYT screens + Travel Rule pre‑checks in Fireblocks/Coinbase/BitGo and bind them into policy engines (no “compliance after the fact”). (fireblocks.com)
Non‑custodial route: call TRM/Chainalysis APIs from your Safe automation (e.g., before Roles‑authorized swaps or payouts). Maintain logs to your subledger.

Legal wrappers that unlock banking, tax, and liability protection

Wyoming DUNA (Decentralized Unincorporated Nonprofit Association), law signed March 7, 2024; effective July 1, 2024
- Gives DAOs legal entity status, ability to contract, pay taxes, and member limited liability; increasingly adopted/considered by large DAOs (e.g., Uniswap’s “DUNI” proposal). (coindesk.com)
Utah DAO Act (LLD) effective January 1, 2024
- Creates a DAO‑native entity (not merely an LLC variant) recognized by the state. (commerce.utah.gov)
Marshall Islands DAO LLC (2022; amended Oct 2023)
- Offshore DAO LLC with Series DAO LLCs for sub‑DAOs; faster registration timelines and explicit clarifications around token/OSS liability. (coindesk.com)
Cayman Foundation Companies
- Used by ENS DAO to interface with off‑chain obligations; DAO retains power to appoint/remove directors via governance. Expect ongoing costs (registered office, supervisor, filings). (docs.ens.domains)

Tip: If you need a U.S.‑friendly structure with public‑goods or protocol‑steward objectives and limited liability for voters, Wyoming DUNA is often the most direct 2025 path; for global operations and IP/tax planning, Cayman foundations remain common.

Treasury accounting and audit readiness (subledger + ERP)

Tres Finance
- 200+ networks, ERP connectors (NetSuite/Xero/QuickBooks), reconciled audit‑ready subledgering and DeFi coverage; built for finance teams rather than engineers. (tres.finance)
Cryptio
- 2025 updates include a derivatives module, expanded staking coverage, and a read‑only “auditor role” to share reports without exposing full platform access. (support.cryptio.co)
Coinbase Prime and custodians supply exportable logs and SOC reports your auditors will ask for; integrate to your subledger monthly. (coinbase.com)

Operational control: require “maker/checker” in the subledger (one team posts, another approves), and reconcile on‑chain balances to custody statements and Safe balances at month‑end.

Examples: concrete setups that work in 2025

U.S.–EU DAO with grants, payroll, and limited DeFi exposure

Legal: Wyoming DUNA for liability + contracts; maintain a Cayman Foundation to hold IP if needed.
Wallets: Safe treasury (4/7) with Zodiac Roles for routine ops; Spending Limits for small vendor payouts.
Custody: Coinbase Prime vault for long‑term assets; enforce transfer policies and video verification for large withdrawals. (help.coinbase.com)
Compliance: TRM Wallet Screening API before Safe‑executed payments; for custodied flows, enable Fireblocks/Prime KYT and Travel Rule where applicable. (trmlabs.com)
Accounting: Tres/Cryptio as subledger; monthly reconciliations and auditor access. (tres.finance)

Protocol DAO with active governance and staking revenue

Legal: DUNA or RMI DAO LLC with Series for working groups.
Custody: Anchorage Digital for governance voting straight from qualified custody plus staking from custody. (anchorage.com)
On‑chain: SafeSnap to make Snapshot proposals executable on‑chain; Roles to confine treasury‑ops interactions to whitelisted DeFi functions with size/frequency caps. (zodiac.wiki)
Monitoring: OpenZeppelin Defender Monitor to alert on critical events (pauses, ownership transfers), with an emergency “pause” action tied to a high‑threshold Safe. Note: Defender new sign‑ups disabled June 30, 2025 with sunset July 1, 2026—plan for migration to OSS Monitor/Relayers. (docs.openzeppelin.com)

AI‑enabled ops agent paying vendors

Safe Allowance module grants the agent 5,000 USDC/day with a whitelist; session keys expire nightly. (help.safe.global)
Pre‑signing policy: address screening via Circle Compliance Engine or TRM; block on high risk. (circle.com)

Emerging best practices we see working

“Pre‑transaction” controls everywhere
- Trigger screening and Travel Rule checks before signature or settlement. If a beneficiary fails KYT or Travel Rule data exchange, auto‑halt. Fireblocks + Notabene wire this into the policy engine; non‑custodial setups can do the same at the bot/relayer layer. (fireblocks.com)
Segregate “cold endowment” and “hot operations”
- Long‑term assets in custody under strict consensus policy; ops float in Safe under Spending Limits/Roles; replenish via scheduled, pre‑approved transfers.
Bind roles to economic limits and contract IDs
- Roles should encode function selectors, target addresses, parameter ranges, call frequency, and maximum exposure. Update roles via governance with a mandatory review window. (docs.roles.gnosisguild.org)
Governance from custody (when feasible)
- If your token holders or foundation hold governance tokens at a custodian, use institutional voting integrations to avoid hot wallets while meeting internal quorum. (anchorage.com)
Keep an “auditor‑ready spine”
- SOC reports from custodians, immutable Safe logs, compliance decisions from KYT/Travel Rule vendors, and a crypto subledger tied to your ERP—so external auditors can trace any payment from proposal → approval → screening → settlement → book entry. (support.cryptio.co)

“Where” to manage treasuries with compliance—shortlist by need

Need qualified custody, internal approvals, Travel Rule, and governance:
- Anchorage Digital; Coinbase Prime; BitGo; Fireblocks (MPC) with Notabene. (anchorage.com)
Need non‑custodial but enforceable on‑chain guardrails:
- Safe + Spending Limits + Zodiac Roles + SafeSnap; session keys for scoped automation. (help.safe.global)
Need app‑embedded wallets with built‑in screening:
- Circle Compliance Engine for Programmable Wallets. (circle.com)
Need KYT/Travel Rule building blocks:
- Chainalysis KYT; TRM Wallet Screening; Notabene SafeTransact/SafeGateway. (chainalysis.com)
Need legal wrapper and off‑chain interface:
- Wyoming DUNA; Utah LLD; RMI DAO LLC (Series); Cayman Foundation (e.g., ENS). (coindesk.com)
Need finance‑grade accounting:
- Tres Finance; Cryptio (auditor role, derivatives, staking). (tres.finance)

Implementation playbook (30/60/90 days)

Days 0–30: baseline controls

Pick wrapper jurisdiction: Wyoming DUNA (US) or RMI DAO LLC (intl). Draft signatory matrices for treasury and governance. (coindesk.com)
Establish custody (Prime/Anchorage/BitGo) for endowment; configure entity/portfolio/transfer policies and allowlists; enable KYT and Travel Rule integrations. (help.coinbase.com)
Deploy Safe treasury (≥3/5 threshold). Install Spending Limits for ≤$10k/day ops; create a “Pause/Circuit‑Breaker” owner in a separate high‑threshold Safe. (help.safe.global)

Days 31–60: automate and bind compliance

Install Zodiac Roles with explicit function/parameter bounds; enable SafeSnap for binding Snapshot votes with a cooldown. (docs.roles.gnosisguild.org)
Add TRM/Chainalysis screening before any Roles‑authorized payment; log every risk decision to your subledger. (trmlabs.com)
Stand up subledger (Tres/Cryptio), map wallets and custody accounts, and sync to ERP; institute maker/checker on postings. (tres.finance)

Days 61–90: governance ops and audits

If holding governance tokens at a custodian, turn on governance voting with internal consensus; document quorum settings. (anchorage.com)
Write a “Treasury Controls” policy: thresholds, approvers, Travel Rule/KYT rules, screening vendors, exception handling, and evidence retention.
Dry‑run a Travel Rule transfer with a counterpart VASP; test failure paths (missing data → auto‑reject) and evidence capture. (notabene.id)

Vendor due‑diligence questions that save time (and problems)

Travel Rule
- Which protocols do you support? How do you handle “sunrise problem” counterparties with no solution? Do you tie authorization to settlement? (notabene.id)
KYT
- How many chains/tokens covered today? Latency of screening? Are indirect exposure thresholds configurable? (chainalysis.com)
Policy engines
- Can we express conditions by destination type, size bands, and asset lists? Is there a change‑control quorum for editing policies? (help.coinbase.com)
Governance from custody (if relevant)
- Snapshot and on‑chain voting coverage; how are approvals recorded for audit? (anchorage.com)
Accounting
- Does the subledger support our DeFi protocols and produce auditor‑ready export with wallet/custody recon? (support.cryptio.co)

What 7Block Labs recommends in 2025

For protocols with material treasuries: split endowment (custody + strict policies) and operations (Safe + Roles + Spending Limits), wire everything through pre‑transaction KYT/Travel Rule checks, and maintain an auditor‑ready subledger.
For DAOs exposed to EU users: align to MiCA/TFR now—enforce the Travel Rule on counterparties and keep consistent data capture. (eba.europa.eu)
For governance: prefer governance‑from‑custody if you have institutional holders; otherwise use SafeSnap with a timelock/cooldown and a circuit‑breaker.

The bottom line: the tech and rules have matured. If you implement the stack above, you can manage a DAO treasury with the same compliance oversight a mid‑market corporate treasury expects—without giving up onchain execution.