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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 VA Management and Investment Services shall establish, implement and enforce appropriate written internal policies and procedures relating to the following—
       
        a. the ability of clients to have access to and withdraw their Virtual Assets including, but not limited to, during periods of high uncertainty and/or extreme volatility;
        b. their assessment of client suitability for relevant products or services, including but not limited to the nature, features, costs and risks of investment services, Virtual Assets or other financial instruments selected for their clients, while taking into account cost and complexity;
        c. how they ensure all Staff providing VA Management and Investment Services to clients are sufficiently competent in accordance with Rule II.B.1 of this VA Management and Investment Services Rulebook; and
        d. such other policies and procedures as VARA may require from time to time.
       
      2. VASPs providing VA Management and Investment Services shall assess and, in any case, at least yearly review the effectiveness of their policies and procedures and take appropriate measures to address any deficiencies.
       

    • B. Public Disclosures

      1. VASPs providing VA Management and Investment 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 as to the ability of clients to have access to and withdraw their Virtual Assets, particularly in times of extreme volatility;
        d. a statement as to the VASP’s arrangements for the protection of clients’ assets held by the VASP and how it determines uses of client Virtual Assets including but not limited to a detailed description of such uses;
        e. a statement as to how they protect client Virtual Assets from counterparty risk;
        f. a statement as to how in the course of the provision on VA Management and Investment Services, client Virtual Assets are used and how clients’ interests in respect of those Virtual Assets are thereby respected;
        g. a statement explaining that client Virtual Assets used by the VASP in the course of the provision of VA Management and Investment Services may be at risk, including the types and nature of such risks, and a statement on the likelihood and severity of any losses which may be suffered;
        h. a statement in relation to order execution by the VASP;
        i. a statement as to how liquidity risk is managed; and
        j. such other information as VARA may require from time to time.
       
      2. Other disclosable matters. To the extent permissible under applicable laws, VASPs providing VA Management and Investment 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 VA Management and Investment 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.