CRA-8.3.2

For the purposes of this Section, licensees should consider, at the minimum, the following two types of crypto-asset wallets:

(a) Custodial Wallet: the custodial wallet provider holds crypto-assets (e.g., the private keys) as an agent on behalf of clients and has at least some control over these crypto-assets. Licensees that hold crypto-assets on behalf of their clients should generally offer custodial wallets and may even offer multi-signature wallets (Paragraph CRA-5.4.5). Clients using custodial wallets do not necessarily have full and sole control over their crypto-assets. In addition, there is a risk that should the custodial wallet provider cease operations or get hacked, clients may lose their crypto-assets.; and
(b) Non-Custodial (Self-Custody) Wallets: the non-custodial wallet provider, typically a third-party hardware add/or software company, offers the means for each client to hold their crypto-assets (and fully control private keys) themselves. The non-custodial wallet provider does not control client’s crypto-assets – it is the client that has sole and full control over their crypto-assets. Hardware wallets, mobile wallets, desktop wallets and paper wallets are generally examples of non-custodial wallets. Clients using non-custodial wallets have full control of and sole responsibility for their crypto-assets, and the non-custodial wallet provider does not have the ability to effect unilateral transfers of clients’ crypto-assets without clients’ authorisation.
Amended: April 2023
Added: April 2019