A. Wind Down Plan

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1.	All VASPs shall have and maintain a wind down plan (“Wind Down Plan”), which shall include the following—
	a.	processes for identifying and mitigating any material risk or obstacles to winding down in an orderly and timely manner;
	b.	an evaluation of the resources that are needed to facilitate an orderly and timely wind down;
	c.	internal controls and procedures to ensure the safekeeping and prompt onward transferring of clients’ Virtual Assets (including returning Virtual Assets to clients);
	d.	personnel management and exit arrangements;
	e.	communications strategy (including the provision of clear and timely disclosures to all clients);
	f.	knowledge transfer as required to support migration of VA Activities and all relevant operations to alternate VASPs;
	g.	system redundancies and retention of records;
	h.	continue to maintain a surety bond until completion of the wind down process;
	i.	discontinue taking on new clients;
	j.	identify and itemise all current and contingent liabilities;
	k.	ensure that the sale of Client Money and/or Client VAs is explicitly excluded from, and not necessary for, implementing or completing the Wind Down Plan, or any other plan, procedures or scheme directed by an Insolvency Appointee, or the sale of the VASP’s assets or business as a going concern; and
	l.	ensure VARA has the power and ability to intervene and/or assume the direction and/or control of Client Money and/or Client VAs at VARA’s election, including but not limited to where the VASP is in breach of any Regulation, Rule or Directive.
2.	In the event that a VASP elects to discontinue its business or operations where it is not Insolvent or subject to Insolvency Proceedings, the VASP must—
	a.	notify VARA not later than one (1) day after such decision;
	b.	provide VARA its latest up-to-date Wind Down Plan at the time of such notification;
	c.	implement the Wind Down Plan, subject to any amendments or additions notified to it by VARA;
	d.	make any further changes notified to it by VARA at any stage throughout the implementation and completion of the Wind Down Plan; and
	e.	report to VARA every week throughout the implementation and completion of the Wind Down Plan; and
	f.	provide all other updates and/or reports as requested by VARA at any time.