CRA-8.2.2

Licensees may implement the following three types of custodial arrangements or any other type of custodial arrangement that is acceptable to the CBB:

(a) The licensee is wholly responsible for custody of client’s crypto-assets and provides this service “in-house” through its own crypto-assets wallet solution. Such an arrangement includes scenarios where a licensee provides its own in-house proprietary wallet for clients to store any crypto-assets bought through that licensee or transferred into the wallet from other sources.
(b) The licensee is wholly responsible for the custody of client’s crypto-assets but outsources this service to a third party crypto-asset custodian. Such an arrangement includes the scenario where a licensee uses a third-party service provider to hold all its clients’ accepted crypto-assets (e.g., all or part of the clients’ private keys).
(c) The licensee wholly allows clients to “self-custodise” their accepted crypto-assets. Such an arrangement includes scenarios where licensees require clients to self-custodise their crypto-assets. Such licensees only provide the platform for clients to buy and sell crypto-assets. Clients are required to source and use their own third party crypto-asset custodians (which the licensee have no control over or responsibility for). This arrangement also includes the scenario where licensees provide an in-house wallet service for clients, but also allow clients to transfer their crypto-assets out of this wallet to another wallet from a third-party wallet provider chosen by the client (and which the licensee does not control).
Amended: April 2023
Added: April 2019