Crypto Advisory Services — Suitability-First, Independent, Evidence-Backed Advice
Offer personal recommendations on Virtual Assets with independent methodology, bias controls, verified facts, and public disclosures that withstand regulatory scrutiny.
Advising VASPs on suitability frameworks, staff competency matrices, conflict management, introducer disclosures, and advice-file QA programs.
WHAT THE VARA ADVISORY LICENCE COVERS
“Crypto Advisory Services” means offering, providing, or agreeing to provide a personal recommendation to a client (on request or on your initiative) in respect of one or more actions or transactions relating to any Virtual Asset.
Note: The Advisory Services Rulebook (ASR) is issued under the Regulations 2023 and applies in addition to the four VARA Compulsory Rulebooks: Company, Compliance & Risk Management (CRM), Technology & Information (TIR) and Market Conduct (MCR); if you hold other VA Activity licences, their rulebooks also apply cumulatively.
SERVICES YOU CAN OFFER UNDER THIS LICENCE
Personal recommendations
On VA transactions or actions (buy/sell/hold/stake/allocate/exit), delivered on request or proactively, subject to client suitability and independent basis requirements.
Mandate-aligned advice
Across multiple VAs, assessing a sufficiently diverse range to meet the client’s objectives.
Cross-activity coverage
where also licensed (e.g., Broker-Dealer, Exchange): Advisory obligations apply alongside those activity-specific rulebooks.
COMPLIANCE GUARDRAILS THAT KEEP YOU OUT OF TROUBLE
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Policies & annual effectiveness review (Part I.A) |
Maintain written policies on: (i) independent basis of advice; (ii) staff competency; plus any others VARA requires. Review at least yearly and remediate deficiencies. |
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Public disclosures (Part I.B) |
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Client suitability & best interest (Part II.A) |
Provide advice in good faith, suitable and in the client’s best interest. Assess at minimum: (i) knowledge/experience with VAs; (ii) objectives (risk tolerance, time horizon, acquisition venues); (iii) financial circumstances (ability to bear sudden/significant losses; % of net worth in VAs). Keep suitability information accurate/up-to-date and retain ≥ 8 years. In each advice, specify why it is appropriate by reference to the assessed factors. Eliminate conscious bias and take reasonable steps to eliminate non-conscious bias. |
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Staff competency (Part II.B) |
Ensure advisers are knowledgeable, competent, suitably trained, considering qualifications, VA-sector experience, regulated-advice experience, understanding of the VARA framework, and industry standards. |
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Verification of information (Part II.C) |
Advice must not contain statements/promises/forecasts that are misleading, false, or deceptive (including what you should reasonably have known). Verify factual information against appropriate and reliable sources and use reasonable endeavours to ensure continued accuracy. |
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Methodology (Part II.D) |
Assess a broad universe of VAs sufficiently diverse to meet the client’s objectives; avoid product-set bias. Document your methodology. |
What CRYPTOVERSE Legal delivers
Licensing strategy memo
(when Advisory is standalone or combined with other VA Activities), mapping cumulative obligations across ASR + Company/CRM/TIR/MCR.
Suitability framework
KYC/suitability questionnaires, profiling rubric, appropriateness tests, 8-year retention records, and “appropriateness-statement” templates to evidence why a recommendation fits.
Independence & conflicts
“independent basis of advice” policy, inducement/introducer registers, disclosures, and QA audits.
Staff competency matrix
Role-based criteria (quals/experience/VARA knowledge), annual CPD plans, assessment logs.
Verification & methodology
Fact-checking SOPs, approved sources list, methodology note covering VA universe selection and diversification tests.
Website disclosure pack
Conflicts; privacy/whistleblowing/complaints; introducer terms & benefits; third-party custodian identity.
OUR PROCESS
(FAST & REGULATOR-READY)
Scoping call
model & activity mapping (order-book, conversion rails, margin).
Regulatory blueprint
Artefact list, Board/committee design, capital & prudential mapping.
Policy build-out
independence, suitability, staff competency, verification/methodology, conflicts/introducers; annual effectiveness plan.
Tech & controls
Advice-file templates, appropriateness statements, disclosure pages.
Regulator interactionS
Responses to information requests; remediation of comments.
Go-live support
QA sampling, CPD tracking, disclosure upkeep, annual reviews.
Why CRYPTOVERSE Legal
Narrow-cast L&B expertise
We translate the Rulebook into pragmatic, auditable controls.
Evidence-ready
Every control is rule-mapped and inspection-proof.
Speed with substance
Timelines compressed without cutting compliance corners.
Speak to a Crypto Lawyer
Book a Strategy CallFAQs
Yes. Advisory applies cumulatively with the rulebooks for your other licensed VA Activities.
Yes—publish the arrangement and the monetary or non-monetary benefits received, in a prominent place on your website.
At least eight (8) years, and keep them accurate and up-to-date.
Written policy + audit trail showing methodology breadth/diversity, conflict controls, and evidence that advice was best-interest and suitable for the specific client.
Role-appropriate qualifications/experience, VA-sector exposure, understanding of VARA’s framework, and ongoing training aligned to industry standards.