401(k) to include crypto: What it means for asset managers

In a landmark move that could reshape retirement investing, President Trump signed an executive order yesterday directing U.S. regulators to allow 401(k) plans to include alternative assets, including cryptocurrency. 

While firms like Fidelity and BlackRock already offer crypto exposure, a growing number of asset managers will now need to evaluate how to integrate digital assets into retirement plans in a secure, compliant, and scalable way. 

This creates opportunities for collaboration with crypto-native firms such as Grayscale, Galaxy Digital, Bitwise, ARK Invest, Valkyrie, and others who are actively building retirement-compatible investment products. Partnering with these firms can provide valuable expertise, established infrastructure, and faster paths to market.

Another viable approach is for asset managers to hold and manage their own crypto investments directly, gaining greater control over transaction policies and operational workflows. Turnkey makes this possible by providing secure, enclave-based infrastructure that lets managers operate with institutional-grade protection while fully owning their custody process.

What’s in the new executive order on 401(k) and crypto

Signed on August 7, 2025, the executive order tasks the Department of Labor, SEC, and Treasury with revising regulatory frameworks to allow alternative asset classes such as cryptocurrency, private equity, and real estate to be included in tax-advantaged retirement plans like 401(k)s.

The directive reverses earlier guidance that discouraged such investments due to fiduciary risk and establishes a regulatory pathway for digital asset exposure in retirement accounts, pending agency implementation.

Implications for asset managers

Asset managers are likely to see growing demand for crypto exposure in retirement plans. To respond effectively, firms will need to:

• Assess internal readiness to develop and manage crypto products
• Engage with regulators and industry associations
• Invest in infrastructure that enables security and control
• Evaluate partnerships with crypto-native firms

As crypto becomes a more common component of retirement portfolios, firms that offer exposure with institutional-grade controls will be better positioned to meet market expectations.

A key consideration for asset managers will be determining how to securely custody crypto assets.

Options in custody for institutional crypto assets

Custodying crypto requires holding a private key, a cryptographic credential that grants control over a digital asset. Whoever holds it is typically deemed to control the asset.

In 401(k) accounts, there are two primary ways to manage crypto and private keys:

Third-party custody: This approach involves partnering with regulated custodians to securely hold and manage crypto assets. Under this model, custodians manage the keys on behalf of the asset manager, providing regulatory clarity, robust security protocols, and established operational processes. 

While it may involve less direct transaction control and can introduce additional costs or slower execution, it also offers the peace of mind of working with seasoned professionals who specialize in safeguarding digital assets.

Non-custody:  A newer approach, non-custody allows firms to retain full control of their private keys. Platforms like Turnkey enable this by isolating private keys in trusted execution environments that no outside party can access.

This model offers a secure, compliant, and scalable way to manage crypto while preserving direct control over assets. Pricing is typically usage-based, making it cost-efficient and predictable, especially for high-volume or automated operations. 

While initial integration is required, the long-term benefits include faster execution, reduced third-party reliance, and tighter alignment with internal controls.

How to choose the right crypto asset partners

Choosing the right partners is important to successfully entering the crypto retirement space. Asset managers should evaluate:

• Security and operational track record
• Custodial licensing and regulatory clarity
• Integration with existing systems and platforms

Many leading crypto firms already offer retirement-ready products and services. However, most rely on traditional custodial models that limit control and flexibility. 

An infrastructure solution like Turnkey offers an alternative: it enables firms to retain ownership of private keys themselves without the operational risk of relying on a third party.

Private keys are stored in secure hardware enclaves and are only accessible via policy-approved actions. This combines the security of custodial infrastructure with the autonomy and scalability needed to build institutional-grade crypto retirement offerings.

Turnkey as the infrastructure solution

For asset managers exploring non-custodial infrastructure, Turnkey offers a robust, compliance-grade solution:

• Enforce policy controls: Define exactly what can be transacted, when, and by whom.
• Isolate keys in secure enclaves: Keep private keys locked in trusted hardware environments.
• Integrate with existing systems: Use Turnkey’s APIs to embed logic into fund workflows or compliance infrastructure.
• Custody without compromise: Retain full key ownership while meeting institutional security and auditability standards.

This enables fund managers to maintain direct control while meeting the expectations of regulators, fiduciaries, and plan sponsors.

Next-gen retirement asset managers use Turnkey

President Trump's executive order marks the beginning of a new chapter for retirement investing. For traditional asset managers, the question is no longer if but how they will integrate crypto into their offerings. 

Success in this environment will require more than just access to the right products; it will demand a secure, programmable foundation that meets the evolving expectations of regulators, plan sponsors, and investors.

For those ready to lead, the infrastructure is already here. Turnkey provides the means for asset managers to enter the crypto retirement space, securely, compliantly, and on their own terms.

Reach out to our team, and get started with Turnkey today. 

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