An exchange proposal should explain how orders, trades, settlement and asset control work. Calling a product an exchange is not a complete description of its activities.[1]
Understanding the question
Map the trading model, participants, matching process and counterparties. Identify whether the operator also performs custody or other services. The application narrative should match the actual system and customer terms. Permission scope and conditions belong to the regulator record.[1]
Build the working record
| Consideration | What to establish |
|---|---|
| Trading model | How are orders brought together and executed? |
| Settlement | Who delivers assets and when is a trade final? |
| Dependencies | Which custody, liquidity or technology providers are involved? |
Put it into practice
A venue with an external custodian needs a clear allocation of trade settlement and asset-control responsibility.
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 supportReferences
Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.
- 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.
- 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.
- 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.