# Custody

Canonical: https://dubaivirtualassetlicenceguide.com/custody/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

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.[\[1\]](https://dubaivirtualassetlicenceguide.com/custody/#ref-vara)

## 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.[\[1\]](https://dubaivirtualassetlicenceguide.com/custody/#ref-vara)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Keys | Who holds signing authority and recovery access? |
| Records | How are balances reconciled to customer entitlements? |
| Incidents | Who can pause, investigate and restore service? |

## Put it into practice

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

**Useful output**: A custody control matrix and a tested operating-procedure set.

## 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.[\[3\]](https://dubaivirtualassetlicenceguide.com/custody/#ref-varaService)[\[4\]](https://dubaivirtualassetlicenceguide.com/custody/#ref-victoria)

[Ape Law’s VARA application support ↗](https://ape.law/services/vara-license-application)

## Continue reading

- [Application preparation — **Outsourcing and vendors →** — Outsourcing does not remove the need to understand who performs and controls a service.](https://dubaivirtualassetlicenceguide.com/outsourcing-and-vendors/)

- [Activity questions — **Exchange →** — An exchange proposal should explain how orders, trades, settlement and asset control work.](https://dubaivirtualassetlicenceguide.com/exchange/)

- [Activity questions — **Advisory →** — An advisory model should state the advice given, the customers served and the decisions the provider influences.](https://dubaivirtualassetlicenceguide.com/advisory/)

## 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 ↗](https://rulebooks.vara.ae/) — 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.
3. [Ape Law: VARA licence applications ↗](https://ape.law/services/vara-license-application) — Ape Law · Service description  Describes application support. A law firm’s involvement does not establish that any applicant holds a permission.
4. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — 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.](https://dubaivirtualassetlicenceguide.com/sources/)