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  • Part I – Policies, Procedures and Public Disclosures

    • A. Policies and Procedures

      1. In addition to all other requirements in the Regulations and Rulebooks, VASPs providing Advisory Services shall establish, implement and enforce appropriate written internal policies and procedures relating to the following—
       
        a. how they ensure the independent basis of their advice;
        b. how they ensure all Staff providing advice are sufficiently competent in accordance with Rule II.B.1 of this Advisory Services Rulebook; and
        c. such other policies and procedures as VARA may require from time to time.
       

    • B. Public Disclosures

      1. VASPs providing Advisory Services shall publish on their website in a prominent place or make available by other publicly accessible means—
       
        a. a detailed description of any actual or potential conflicts of interest arising out of their activities, and how these are managed;
        b. their policies and procedures relating to data privacy, whistleblowing and handling of client complaints;
        c. a statement of whether the VASP refers or introduces clients to other Entities including, but not limited to, other VASPs, and if so, a description of the terms of such arrangements, and the monetary or non-monetary benefits received by the VASP, including by way of reciprocation for any service or business; and
        d. a statement of whether the VASP has accounts, funds or Virtual Assets maintained by a third party and if so, provide the identity of that third party.
       
      2. Other disclosable matters. To the extent permissible under applicable laws, VASPs providing Advisory Services shall publish on their website or by other publicly accessible means—
       
        a. details of any past convictions or prosecutions of any member[s] of their Senior Management or Board, whether before the courts of the UAE or the courts of another jurisdiction; and
        b. any such other information relating to their business or activities as VARA may reasonably require.
       
      3. The disclosure requirements set out in this Rule I.B of this Advisory Services Rulebook are in addition to all disclosures required under the Market Conduct Rulebook and to all notifications to VARA required under the Compliance and Risk Management Rulebook.