Steering Committee — Operations Technology
Program Status & Risk Review
February 2026  ·  Senior Business & Technology Leadership
Overall Status
AMBER
Critical — Regulatory Deadline
CFTC Digital Asset Reporting Rule
Effective 1 May 2026
Amended Part 43 & Part 45 reporting requirements now explicitly cover digital asset commodity transactions. Galaxy's institutional swaps and on-chain derivatives require field-level schema updates — UPI taxonomy extension, new asset class identifiers, and revised continuation data for crypto positions. Non-compliance triggers mandatory CFTC notification and potential trading suspension.
Gap to Deadline
10 weeks UAT required by Apr 1
Decision Required from SteerCo:
Approve dedicated engineering sprint (3 engineers, 6 weeks). Confirm DTCC GTR test environment access. Sign off on regulatory data mapping specification by 28 Feb.
At Risk — Operational Impact
Settlement Instruction Automation
6-Week Delay · Active Ops Impact
API-based settlement instruction generation to prime brokers and custodians was scheduled for January 2026. Integration dependency on counterparty SSI database refresh has slipped. Operations team currently generating instructions manually — adding 2–3 hours daily overhead, increasing T+1 fail rate by ~18%, and creating reconciliation tail risk on unmatched positions.
Current Operational Exposure
Daily manual overhead+2–3 hrs/day
T+1 fail rate increase+18%
Revised deliveryMarch 14, 2026
Decision Required from SteerCo:
Approve interim manual SLA framework to manage counterparty expectations during delay. Confirm priority escalation with technology vendor for SSI database API access.
Strategic — Operational Evolution
On-Chain Reconciliation Engine
Enabled by Helios Phase 1 · Q2 2026
With Helios Phase 1 node infrastructure provisioned, Galaxy will have direct blockchain API access to reconcile internal book-of-records positions against on-chain wallet balances in real time. This eliminates the overnight batch reconciliation cycle for digital assets — reducing T+0 break discovery from 18 hours to under 5 minutes, and anchoring audit trail on-chain for regulatory examination readiness across CFTC, SEC, and HKMA jurisdictions.
Projected Operational Gain
Break discovery time18 hrs → <5 min
Manual recon FTE reduction~40%
Target go-liveQ2 2026
Decision Required from SteerCo:
Approve engineering resourcing plan for blockchain node API integration. Confirm cross-team dependency with Helios infrastructure team for Q1 2026 node readiness sign-off.
Deliverables & Milestones — Current Quarter
Workstream Milestone Owner Target Status Ops Impact if Missed
CFTC Digital Asset Reporting Data mapping spec signed off NY Ops Tech 28 Feb 2026 Not Started Compliance breach — mandatory CFTC notification
CFTC Digital Asset Reporting UAT complete & DTCC GTR validated NY Ops Tech + Engineering 1 Apr 2026 At Risk Go-live by May 1 not achievable
Settlement Instruction Automation SSI database API integration complete Technology 14 Mar 2026 Delayed Continued manual overhead + T+1 fail exposure
Settlement Instruction Automation End-to-end automation live (all prime brokers) NY Ops Tech 31 Mar 2026 At Risk Q2 regulatory reporting cycle impacted
Reconciliation Engine Rebuild Intraday recon engine pilot (crypto positions) NY + HK Ops 31 Mar 2026 In Progress Overnight batch continues — no immediate breach
Helios / On-Chain Recon Blockchain node API access confirmed Helios Infra Team 31 Mar 2026 Pending On-chain recon Q2 delivery at risk if slips
AI Exception Triage ML classifier reaches 92% accuracy threshold AI/ML Team 30 Apr 2026 In Progress Manual triage continues — currently at 84%
Top Risks
CFTC Compliance Breach
HIGH · Regulatory
Digital asset reporting rule effective May 1. Current state: schema not updated. No UAT environment active. 10-week runway is tight given cross-team dependencies.
Mitigation: Dedicated sprint approval + DTCC GTR test access by EOW
Settlement Fail Rate Escalation
MED · Operational
Manual settlement instruction process creating 18% elevated T+1 fail rate. Counterparty relationships at risk if fail rate continues past Q1 close. Reputational exposure with prime brokers.
Mitigation: Interim SLA framework + vendor escalation on SSI API
Helios Infrastructure Dependency
MED · Strategic
On-chain reconciliation engine Q2 delivery depends entirely on Helios Phase 1 node provisioning. Any slip in data center timeline cascades directly to ops tech roadmap.
Mitigation: Formal dependency tracking with Helios program lead. Bi-weekly sync established.
Decisions Required from This Meeting
Approve CFTC Sprint — Engineering Resource Allocation
URGENT
3 engineers, 6 dedicated weeks. Must start by Mar 2 to hit Apr 1 UAT deadline. Competing with Settlement Automation workstream for same engineering pool.
Sign Off Regulatory Data Mapping Specification
BY 28 FEB
Legal, Compliance, and Operations Technology joint sign-off. Blocks all downstream engineering work until approved.
Authorize Interim Manual Settlement SLA Framework
THIS WEEK
Formalize counterparty communication on manual process through Mar 14. Prevents client escalations. COO and Institutional Sales alignment needed.
Confirm Helios Node Readiness Commitment — Q1 2026
STRATEGIC
Formal commitment from Helios program to deliver blockchain node API access by Mar 31. Required to protect Q2 on-chain recon delivery.
Next Steps & Follow-Up
Immediate (This Week)
→ CFTC data mapping session with Compliance
→ Engineering sprint plan submitted for approval
→ DTCC GTR test environment access request filed
→ Counterparty communications on settlement SLA
March
→ Settlement instruction API integration delivered
→ CFTC schema UAT environment stood up
→ Helios API access confirmed and documented
→ Intraday recon pilot results reviewed with Ops
April — Q2 Setup
→ CFTC UAT complete — production go-live May 1
→ ML exception triage target 92% accuracy
→ On-chain recon engine design phase complete
→ Full settlement automation across all PBs live