VIRTUAL ASSETS MANAGEMENT & INVESTMENT SERVICES UNDER VARA

Operate discretionary and managed VA mandates with institutional-grade controls, monthly client reporting, and robust public disclosures—fully aligned to VARA’s  Regulations.

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Request the VARA Management & Investment Services Checklist.

Advising VASPs on suitability frameworks, staff competency matrices, conflict management, introducer disclosures, and advice-file QA programs.

WHAT THIS LICENCE COVERS

Under VARA’s VA Management and Investment Services Rulebook, licensed VASPs may manage clients’ Virtual Assets and provide investment management services—subject to cumulative compliance with all cross-cutting Rulebooks (Company, Compliance & Risk Management, Technology & Information, Market Conduct). The Management & Investment Services Rulebook applies in addition to those frameworks.

SERVICES YOU CAN OFFER UNDER THIS LICENCE

When properly licensed by VARA for VA Management & Investment Services, your firm can deliver:

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Discretionary VA Portfolio Management

Execute a defined mandate (strategy, assets in scope, risk/limits), acting at all times in the client’s best interests (price, costs, speed, likelihood of execution/settlement, custody conditions).

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Non-Discretionary/Advisory-Led Mandates

Provide personal recommendations within the management relationship, after assessing knowledge/experience, objectives, risk tolerance, time horizon, financial circumstances; document appropriateness and keep records.

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Receipt & Transmission of Client Orders

Related to managed VA positions, with prompt transmission and no remuneration for routing unless disclosed in the Client Agreement and accepted per law.

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Independent Valuation & Monthly Client Statements

Maintain independent valuation and send monthly statements covering holdings, period transactions, and valuation changes.

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Liquidity & Market-Risk Management

Monitor/test liquidity and market risk regularly; put corrective measures in place; subject risk and due-diligence processes to independent third-party audit.

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Transparent Fees & Charges

Charge only as permitted under the Client Agreement; give 90 days’ prior notice before introducing a new fee category or increasing rates payable out of managed VAs.

Important guardrail: You must not represent that management services involve distributing protocol “staking rewards” unless client payments directly originate from protocol-level rewards.

COMPLIANCE GUARDRAILS THAT KEEP YOU OUT OF TROUBLE

Policies & Procedures (Part I.A).

Maintain written policies that cover, at minimum:

  • Client access/withdrawals to/from managed VAs (including during high volatility).
  • Client suitability methodology (nature/features/costs/risks; cost & complexity considerations).
  • Staff competency standards and training for anyone delivering management/investment services.
  • Annual effectiveness review and remediation.

Public Disclosures (Part I.B)

Prominently publish on your website:

  • Conflicts of interest and how they’re managed.
  • Privacy, whistleblowing, complaints policies.
  • Client access/withdrawal statements (esp. in stress).
  • Client-asset protection arrangements; uses of client VAs and how you mitigate counterparty risk.
  • How client VAs are used in management and how clients’ interests are respected; clear risk statements about potential losses when VAs are used in the course of services.
  • Order-execution and liquidity-risk statements; any other disclosures VARA requires.

Where legally permissible: past convictions/prosecutions of Senior Management/Board; and any other information VARA reasonably requires. (These are in addition to Market Conduct and Compliance & Risk notification duties.)

Client Suitability (Part II.A)

Client Suitability (Part II.A)

Staff Competency (Part II.B)

Ensure staff are knowledgeable, competent, trained, considering qualifications, VA sector experience, understanding of VARA’s framework, and industry standards.

Truth in Information (Part II.C).

Verify facts before making statements/promises/forecasts; do not provide information that is, or should reasonably be known to be, misleading/false/deceptive; keep information current.

 Impermissible Activities (Part II.D).
  • No rehypothecation of client VAs without explicit prior consent.
  • Use or exercise authority only with valid authorisation/specific client instructions.
  • Client VAs used in the course of services are held on behalf of the client, unless the Client Agreement expressly states otherwise.

Reporting & Valuation (Part II.E).

 Monthly statements; independent valuation of all assets under management; documented valuation policy to ensure timely, accurate valuations.

Fees & Charges (Part II.F).

Charge from client VAs only as permitted by Client Agreement; 90-day notice before new fee categories or increases.

 Management Practices (Part II.H) & RTO (Part II.I).
  • Act in the client’s best interests at all times; follow any specific instructions.
  • Promptly transmit client instructions; no routing remuneration unless disclosed/accepted; do not misuse client information.

Risk & Diligence (Part II.J).

Monitor/test liquidity and market risks regularly; remediate promptly; have the framework independently audited and provide to VARA on request.

Client Agreements (Part II.K).

Agreements must clearly set out, among other items:

In-scope VAs; rights of VASP/client/other entities (incl. staking); payment of proceeds (and variability/rules); whether client VAs are held on behalf of the client; explicit client consent for any use of VAs; withdrawal rights; clear risk statements (likelihood/severity); rights to vary/terminate and consequences; valuation fluctuation terms; events of default; complaints process; and whether you receive routing benefits.

What CRYPTOVERSE Legal delivers

Licence-ready pack

Policies, procedures, and website disclosure suite that map one-to-one to Part I.A/B requirements

Mandate design & suitability toolkit

Client-fact-find, risk-profiling, appropriateness reasoning notes, and 8-year retention model (Part II.A).

Client Agreement templates

Aligned to Part II.K, including optional staking use-cases with explicit, informed consent language.

Valuation & reporting playbook

Independent valuation SOPs and monthly statement artefacts (Part II.E).

Risk & diligence framework

Liquidity/market-risk MI, independent audit scoping, and board reporting (Part II.J).

Marketing clearances

Staking-claims controls and fair-presentation sign-off (Part II.G/C).

OUR PROCESS
(FAST & REGULATOR-READY)

Scope & perimeter

Define in-scope VAs, mandate types, custody model.

Policy stack build

Part I.A policies; cross-references to Company/Compliance/Tech/Conduct Rulebooks.

Disclosures & website

Implement Part I.B public disclosures; conflicts, custody/use, execution & liquidity statements.

Client Agreement & consent

Embed Part II.K terms; staking/use of VAs only with clear consent.

Valuation & reporting

Independent valuation; monthly client statements; audit trail.

Readiness review

Evidence pack, independent audit scoping (risk & diligence), and go-live briefing for senior management.

Why CRYPTOVERSE Legal

VARA-first specialists

We build to the letter of the Rulebook, then operationalise it.

Evidence-driven

Disclosure pages, monthly reports, and audit trails that satisfy Part I & II expectations.

Speed with substance

Regulator-ready artefacts without sacrificing client-protection outcomes.

Ready to launch a compliant VA management proposition?

Book a Strategy CallRequest the VARA Management & Investment Services Checklist

FAQs

Any recommendation made to a specific client that they should take a course of action in relation to VAs within the management service—triggering the suitability factors and record-keeping (≥8 years).

Only with explicit prior client consent. Otherwise, client VAs used during service provision are held on behalf of the client, unless the Agreement states otherwise.

Monthly, including total value, all period transactions, and valuation changes; maintain independent valuation and a documented valuation policy.

Only if the Client Agreement discloses this and valid acceptance is obtained; otherwise, no remuneration for routing.

Conflicts/management, privacy/whistleblowing/complaints, access/withdrawal during stress, client-asset protection & uses, counterparty-risk mitigation, how client VAs are used (and risks), order-execution, and liquidity-risk statements—plus any additional items VARA requires.