Virtual Assets Standards
Table of Contents
1. INTRODUCTION
2. PURPOSE
The purpose of this document is to lay down the procedures to be followed to accept a digital
asset for securing within Liminal’s infrastructure and also the criteria for acceptance/removal.
3. TYPES OF CUSTODY
- Qualified (full) Custody – This type of custody refers to the practice where Liminal assumes complete responsibility of storage, management and security of digital assets for its clients.
- Self-Custody – This type of custody refers to the practice where Liminal’s clients are entrusted with complete control and management of their digital assets.
4. ASSET ACCEPTANCE PROCESS FOR QUALIFIED (FULL) CUSTODY
Liminal employs two kinds of custody models in order to serve its clients. They are:
4.1 Negative list of Assets
4.2 Crypto Currency Assets acceptance
The asset acceptance process for full custody involves assessing the below criteria:
- Maturity / Market Capitalisation
- Security
- Traceability / Monitoring
- Exchange Connectivity
- Type of Distributed Ledger (DLT)
- Innovation / Efficiency
- Practical Application / Functionality
Criteria | Description |
---|---|
Maturity / Market Capitalisation | The sufficiency, depth and breadth of client demand, the proportion of the Virtual Asset that is in free float, and the controls/processes to manage volatility of a particular Virtual Asset. The factor will also take into account the due diligence on the development team, reputation of the asset and track record. |
Security | Consideration of whether a specific Virtual Asset is able to withstand, adapt, respond to, and improve on its specific risks and vulnerabilities, including relevant factors/risks relating to the on-boarding or use of new Virtual Assets (including size, testing, maturity, and ability to allow the appropriate safeguarding of secure private keys), screen whether the virtual asset was involved in a security breach which may render the chain insecure, the chain has mechanisms to resolve incidents and failures. |
Traceability / Monitoring | Whether there are (other) exchanges that support the Virtual Asset; the .jurisdictions of these exchanges and whether these exchanges are suitably regulated. |
Type of Distributed Ledger (DLT) | Whether there are issues relating to the security and/or usability of a DLT used for the purposes of a Virtual Asset; the type of consensus mechanism, whether the Virtual Asset leverages an existing DLT for network and other synergies; whether a new DLT has been demonstrably stress tested. |
Innovation / efficiency | Whether the Virtual Asset helps to solve a fundamental problem, addresses an unmet market need or creates value for network participants. |
Practical Application Functionality | Whether the Virtual Asset possesses real world, quantifiable application / functionality, whether the asset addresses any use cases or enables any Functionality |
5. Procedure of accepting the Assets on the platform:
5.1 ASSESSMENT OF THE ASSETS
The assessment for an asset for its eligibility to be an accepted asset is derived based on all the factors listed above. The assessment and due diligence on the asset proposed to be supported for custody are carried out by the Product team, Technology Officer, Risk Officer, Operations Officer overseen by the Senior Executive Officer. In addition to the above assessment factors, FAC considers below while assessing the asset acceptance which are :
i. its design, features and use cases [whether or not intended by the Issuer or
relevant developers];
ii. whether there are features which may materially affect First Answer Custody’s compliance with applicable laws, Regulations, Rules or Directives, including but not limited to those relating to AML/CFT, sanctions, securities,
intellectual property;
iii. regulatory treatment by VARA and other appropriate authorities [including those outside of the Emirate], in particular whether the issuance of the VA has received any regulatory approvals;
iv. whether a Virtual Asset is prohibited by VARA or any other appropriate authorities [both inside or outside the UAE] in jurisdictions in which First Answer Custody will provide VA Activities, or equivalent activities, in relation to such Virtual Asset;
v. its future development [e.g. roadmap] as communicated by the Issuer and/or relevant developers;
vi. whether it may be susceptible to price manipulation for any reason and relevant mitigations that will be implemented by First Answer Custody;
vii. whether potential or actual conflicts of interest may arise should First Answer Custody provide any VA Activities in relation to the Virtual Asset and relevant mitigations;
viii. the background of its Issuer including, but not limited to, relevant experience in the Virtual Asset sector and whether it has been subject to any investigations or claims in relation to fraud or deceit;
ix. if the Virtual Asset represents rights to any other assets, the enforceability of such rights;
x. First Answer Custody must maintain all records relevant to such assessments for eight [8] years and provide such records for VARA’s inspection upon request.
xi. First Answer Custody shall notify VARA as soon as possible after becoming aware that a Virtual Asset no longer meets its VA Standards and shall take such steps as VARA may direct to minimize any adverse impact on clients arising as a result.
5.2 ASSET ACCEPTANCE
5.3 ONGOING MONITORING
5.4 ASSET REMOVAL
- The asset no longer meets the acceptance criteria
- The asset is associated with any illegal or fraudulent activity
- The asset issuer fails to meet security or operational requirements
- The asset violates any policies of Liminal
- The objective of the asset is found to be involved with Ponzi schemes, marketing
schemes aimed at defrauding the investors or users - There is any adverse news about the chain or the assets or the team behind the development and issue of the assets.
6. ROLES AND RESPONSIBILITIES PRODUCT
OFFICER
OPERATIONS OFFICER
RISK OFFICER
TECHNOLOGY OFFICER
SENIOR EXECUTIVE OFFICER
BOARD OF DIRECTORS
7. ASSET ACCEPTANCE ON FORK SITUATIONS
The following scenarios shall arise with decision making on the part of Liminial,
1. Accept new Virtual Asset(s) in addition to the existing Virtual Asset
2. Not to accept the new Virtual Asset(s) and continue to support the existing Virtual Asset
3. Accept new Virtual Asset(s) and not to accept the existing Virtual Asset
4. Not to accept new Virtual Asset(s) and existing Virtual Asset