Big 4 Ask Employees to Disclose This Year’s Crypto Investments ‘Details to Go in Common Database’

The Big Four professional services firms –Deloitte, PwC, EY and KPMG- have asked their executives and partners to disclose cryptocurrency investments made by them or their family members during the year.

As part of annual risk-assessment process, the firms have also sought details of investments in non-fungible tokens or other crypto assets.

In at least two of the Firms-Deloitte and PwC-partners have been told to disclose investments as small as Rs10 in such assets, said people with Knowledge of the matter. The firms fear conflict of interest if partners or any of their family members have bought crypto asset, said insiders.

“Most of these investment is done by the executives and young partners as most of the older ones stick to traditional investment s such as equity and real estate’ said a senior partner at one of the firms. “But we want to be above board as many of our projects involve directly working with the Reserve Bank of India (RBI) and the government.

Take the case of a young tech partner at a large firm who bought some cryptocurrency to learn how the system works. “It’s not like I invested Millions-I bought a few cryptocurrencies to understand the technology and how it works so that I get better clarity when we work on block chain project. I had to disclose everything and the firm actually told me to stay away from stable coins,” he said.

Stable coins are cryptocurrencies whose value is derived from an underlying asset- dollars or gold in most cases.

Insiders say that while even executives are asked to disclose crypto investments, the focus is mainly on partners. There are about 1,600 partners in the Big Four firms who head certain service functions such as consultancy, taxation or audit.

Until now, partners were asked to disclose all their liabilities and assets every year. These include investments such as equity, mutual funds and now cryptocurrency.

PwC has asked Every employee, including associates, to disclose investments in cryptocurrencies.

“Everyone has to put these transactions in the common database,” a senior executive said.   

“In Our firm, we have to submit bank statements. So let’s assume that a partner has bought crypto assets but hasn’t disclosed it. And if that gets caught, it could lead to trouble,” said a tax partner at a large firm.


None of the firms have however specifically asked any of their employees or partners to abstain from investing in cryptocurrencies.

In one case, an executive was questioned after it was found that her husband may have bought some cryptocurrencies worth around Rs. 10,000 in July this year.

“The compliance department found this out. The executive was asked to cough up a fine of Rs. 25,000 for not disclosing this information,” Said a person with direct knowledge of the matter.

In all the Big Four firms, the compliance department consists of 100 to 150 people tasked with verifying whether partners are making full disclosures.

“It’s best to disclose everything, as otherwise there are various degrees of punishments where level 1 is just a warning but level 4 is a stackable offence,” another partner told ET. An email sent to the Big Four firms on Saturday didn’t get a response. In some cases, the compliance department even mandates that partners do not take housing loans from certain banks as even that could result in a conflict situation, the tax partner said.

For instance, after a senior partner at one of the Big Four firms was chosen CEO, he was asked to liquidate some mutual fund investments as the firm worked for the asset management company.

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