Custody & Administration Policy

Custody and Administration Policy Summary

This summary outlines Whitely’s approach to the safekeeping and administration of client crypto-assets, including internal controls, segregation, reporting, client rights, and regulatory compliance (e.g., MiCA).

Purpose

This document provides a summary of Whitely’s custody and administration policy for the safekeeping and administration of client crypto-assets. It describes the internal rules, procedures, and measures implemented to safeguard assets, maintain operational transparency, and ensure compliance with applicable regulations.

Safekeeping and Control of Crypto-Assets

Whitely securely holds client crypto-assets and related access credentials (including private keys). Access to client assets is limited to authorized personnel and is protected with multi-factor authentication (MFA) and role-based access control (RBAC).

Risk Mitigation Measures

Whitely applies layered safeguards to reduce risks related to fraud, cyber threats, and operational failures. Measures include continuous transaction monitoring, encryption of sensitive data, strict change-management, and insurance coverage designed to mitigate losses arising from theft or loss of assets.

Segregation of Client Assets

Client assets are segregated from Whitely’s own assets. Client holdings are kept in distinct and identifiable wallets to ensure clear ownership and to protect clients in the event of Whitely’s insolvency.

Transparency and Reporting

Clients receive clear and accurate statements on positions, movements, and balances at least every three months, on request, or via their Account. Whitely also informs clients of events that may affect their rights or assets, including changes in asset positions or rights.

Client Rights and Access

Whitely assists clients in exercising rights attached to their crypto-assets, including access or control in the event of protocol changes or other relevant events. Rights to newly created assets arising from blockchain upgrades are preserved for clients.

Security Systems and Procedures

Whitely employs a comprehensive security framework, including private key encryption, access segregation, and ongoing risk management practices, to protect client assets from unauthorized access and cyber threats.

Return of Assets

Upon client instruction, Whitely facilitates the prompt and secure return of crypto-assets or the means of access (e.g., private keys), following defined protocols to maintain asset security.

Compliance with Regulations

Whitely complies with relevant legal and regulatory requirements, including Regulation (EU) 2023/1114 (MiCA), covering the custody and administration of crypto-assets, segregation, reporting, and risk management.