A licensee that maintains custody or control of crypto-asset must avoid conflict of interest between its function as a crypto-asset custodian and any other activities. With an objective to avoid or mitigate actual or potential conflict of interest between its custody function and any other activities, the licensee must adopt a governance structure that ensures adequate management of conflicts of interest crypto-asset custody activity is fully independent from its other activities. Such governance structure must include, among other things, having separate staffing arrangements to undertake the crypto-asset custody activity, who do not have any conflicting responsibilities within the licensee’s other activities.