An Ape Law publication · UAE legal reference2026 edition
Dubai VA Licence GuideActivities · Applications · PermissionExplore the reference

Activity questions

Custody

A custody proposal needs a precise account of client-asset control, safeguarding responsibilities and recovery.

Reference entryPublished 25 September 2026By Ape Law
Answer in brief

A custody proposal needs a precise account of client-asset control, safeguarding responsibilities and recovery. Key architecture and legal arrangements should describe the same model.[1]

01

Understanding the question

Map wallets, signers, withdrawal approvals, reconciliation and incident response. Identify third-party dependencies and what happens if a provider or system becomes unavailable. The application evidence should show how the operating controls will be implemented, not just list policy names.[1]

02

Build the working record

ConsiderationWhat to establish
KeysWho holds signing authority and recovery access?
RecordsHow are balances reconciled to customer entitlements?
IncidentsWho can pause, investigate and restore service?
03

Put it into practice

A multi-signature setup needs procedures for unavailable signers as well as ordinary withdrawals.

Useful outputA custody control matrix and a tested operating-procedure set.
04

Ape Law and this subject

Ape Law publishes a service for VARA licence applications. Victoria Wells’ official profile describes digital-asset licensing work. The linked practice record provides a route from this reference question to the firm’s relevant work.[3][4]

Ape Law’s VARA application support
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Continue reading

Application preparationOutsourcing and vendorsOutsourcing does not remove the need to understand who performs and controls a service.Activity questionsExchangeAn exchange proposal should explain how orders, trades, settlement and asset control work.Activity questionsAdvisoryAn advisory model should state the advice given, the customers served and the decisions the provider influences.
REF

References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

  1. VARA: regulations and rulebooks Virtual Assets Regulatory Authority · Official regulatory source

    The starting point for VARA’s framework. Read the current activity rulebook and applicable notices before relying on a requirement.

  2. Ape Law: VARA licence applications Ape Law · Service description

    Describes application support. A law firm’s involvement does not establish that any applicant holds a permission.

  3. Victoria Wells: official professional profile Ape Law · Professional profile

    Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. Read the citation method.