| 1. |
Client VAs means all Virtual Assets held or controlled by a VASP on behalf of a client in the course of, or in connection with, the carrying on of any VA Activity, except for—
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a. |
Virtual Assets immediately due and payable to a VASP for the VASP’s own account, such as fees for services provided to a client; |
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b. |
amounts payable by the VASP for expenses incurred on behalf of the client; and |
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c. |
other charges that are due and payable to the VASP.
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| 2. |
Client VAs are held or controlled by a VASP if they are—
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a. |
directly held by the VASP in an account or VA Wallet; |
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b. |
held in an account or VA Wallet in the name of the VASP; |
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c. |
held by a legal entity, or in an account or VA Wallet in the name of a legal entity, controlled by the VASP; or |
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d. |
the private keys and/or seed phrase of the VA Wallet are held or controlled by the VASP.
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