| 1. |
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 will implement a wind down plan, subject to approval by VARA, which shall include the following—
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a. |
processes for identifying and mitigating any material risk or obstacles to winding down in an orderly and timely manner; |
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b. |
an evaluation of the resources that are needed to facilitate an orderly and timely wind down; |
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c. |
internal controls and procedures to ensure the safekeeping and prompt onward transferring of clients’ Virtual Assets [including returning Virtual Assets to clients]; |
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d. |
personnel management and exit arrangements; |
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e. |
communications strategy [including the provision of clear and timely disclosures to all clients]; |
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f. |
knowledge transfer as required to support migration of VA Activities and all relevant operations to alternate VASPs; |
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g. |
system redundancies and retention of records; |
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h. |
continue to maintain a surety bond until completion of the wind down process; |
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i. |
discontinue taking on new clients; and |
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j. |
identify and itemise all current and contingent liabilities.
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