Crypto Custody Services — Institutional-grade Safekeeping, Segregation & Verified Instructions
Launch (or upgrade) a VARA-compliant custodian with per-client wallet segregation, zero rehypothecation, verified-instruction workflows, and audit-ready key management.
Staking-from-custody, collateral wallets for exchange settlement, wallet/key ceremonies, client agreements & public disclosures — end-to-end.
WHAT THE VARA BROKER-DEALER LICENCE COVERS
Under VARA, Broker-Dealer Services let a VASP:
Under VARA, Crypto Custody Services means safekeeping Virtual Assets for, or on behalf of, another Entity, acting only on verified instructions from the client or an authorised agent. Only VASPs that segregate each client’s assets in separate VA Wallets qualify for a Custody Services Licence. The Custody Rulebook adds to the Company, Compliance & Risk, Technology & Information, and Market Conduct Rulebooks.
SERVICES YOU CAN OFFER UNDER THIS LICENCE
Core safekeeping with verified instructions
Operate separate VA Wallets per client, execute only on verified instructions (incl. agent authority), and maintain control of each VA at all times. Rehypothecation is prohibited — and you must not seek client consent to rehypothecate.
Staking from Custody (optional; same legal entity)
If explicitly authorised on your Licence, you may stake on behalf of clients as a sub-set of Custody: per-client wallet segregation continues; single client per node (no pooling); keep withdrawal-key control; set DLT Standards; issue a separate Risk Disclosure Statement and add the required Client Agreement terms.
Collateral Wallet Services (optional; exchange settlement)
If authorised, provide designated CWS Client VA Wallets to net-settle positions with a VARA-licensed Exchange (one Exchange per CWS wallet). Issue receipts at instruction and completion, disclose fee breakdowns, and meet monthly reporting/notification duties to VARA.
COMPLIANCE GUARDRAILS THAT KEEP YOU OUT OF TROUBLE
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Entity separation. |
The Custodian must be an independent legal entity from any Group member conducting other VA Activities (limited exception where VARA authorises Transfer & Settlement Services with strict operational segregation). |
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Policies + annual effectiveness review. |
Maintain written policies enabling client access/withdrawals even in extreme volatility; review at least yearly and fix deficiencies. |
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Public website disclosures (prominent). |
Conflicts & how you manage them; privacy/whistleblowing/complaints; identity of any third-party holder/custodian; “other disclosables” (e.g., certain convictions) where lawful. These sit in addition to Market Conduct disclosures and CRM notifications. |
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Wallet & key management. |
Document hot/warm/cold logic; independent audits; secure key generation and backup practices; multi-sig where appropriate; collusion-risk mitigation; lost/stolen key runbooks (recovery, client notices, LEA cooperation, wind-down). |
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Client Agreements — mandatory content. |
Custodial framework; fork handling; return & settlement finality; statement cadence & content; who secures the VAs; outsourcing & cyber/privacy; access-safeguards; monthly statements; 8-year audit trail retention. |
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Staking from Custody — add-ons. |
Explicit authorisation; continue all custody rules; client-specific instruction (no opt-out); single-client node; DLT Standards set/monitored; immediate suspension & client/VARA notice if a DLT no longer meets standards; separate staking risk disclosure and expanded Client Agreement terms. |
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Collateral Wallet Services — add-ons. |
Explicit authorisation; CWS-designated wallets; one Exchange per CWS wallet; receipts (at instruction & completion); co-mingling risk disclosure; monthly reports to VARA; immediate notifications on reconciliation/recording errors or system delays. |
What CRYPTOVERSE Legal delivers
Licensing strategy & submissions
Activity mapping, RBP alignment, capital/prudential scoping, margin/advisory endorsements where applicable.
Best-Execution & routing framework
Policy, venue-selection logic, quarterly quality-of-execution review process, MI dashboards, and audit trail templates.
Wallet/key-management framework
Hot/cold policies, key-ceremony scripts, multi-sig matrices, collusion-mitigation controls, compromise/IR playbooks.
Staking-from-custody suite
DLT Standards library, single-client-node architecture, staking RDS, Client-Agreement inserts, suspension/exit playbooks.
Collateral Wallet Services docs
CWS Client-Agreement terms, receipt templates, single-Exchange mapping, monthly VARA reporting pack.
Public-disclosure
Conflicts, privacy/whistleblowing/complaints, third-party custodian identity, plus Market Conduct/CRM overlays.
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
Market-abuse, withdrawals in stress, settlement/clearing, pricing methodology.
Tech & controls
Venue rules, surveillance, capacity & BCP/DR, erroneous-order threshold
Regulator interactionS
Notifications and submissions (surveillance, fee model, board reporting).
Go-live support
Public disclosures, periodic reviews, tabletop drills.
Why CRYPTOVERSE Legal
Narrow-cast expertise
We live inside VARA’s trading, principal, distribution, and margin rules — so your controls read like they were drafted in-house.
Evidence-ready documentation
Every control is mapped to a rule and leaves a clear audit trail.
Speed with substance
We compress timelines without cutting corners — from policy stacks to website disclosures.
Speak to a Crypto Lawyer
Book a Strategy CallFAQs
No. Custody requires per-client segregated wallets; for staking, no pooling — one client per node/instance.
Yes — the Custodian must be independent of other VA Activities (limited exception for VARA-approved VA Transfer & Settlement with strict separation).
No. Rehypothecation is prohibited and you must not solicit consent for it.
At least monthly client statements and an 8-year audit trail with date/time, transaction type, signatories and VA details.
It enables staking as part of custody — with added rules (client instruction, segregation, single-client node, DLT Standards, risk disclosure, contract inserts).
Designated CWS Client VA Wallets, one Exchange per CWS wallet, dual receipts, co-mingling risk disclosure, monthly VARA reports, and immediate incident notifications.