| 1. | “Client Money” means all money owned by a VASP’s client which is held or controlled by a VASP on behalf of such client in the course of, or in connection with, the carrying on of any VA Activity, except for—
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| | a. | money which is immediately due and payable to a VASP for the VASP’s own account, such as fees for services provided to a client; |
| | b. | amounts payable by the VASP for expenses incurred on behalf of the client; and |
| | c. | other charges that are due and payable to the VASP.
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| 2. | Client Money does not include any Virtual Assets held by a VASP on behalf of a client. |
| 3. | Client Money is held or controlled by a VASP if it is—
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| | a. | directly held by the VASP; |
| | b. | held in an account in the name of the VASP; or |
| | c. | held by an Entity, or in an account in the name of an Entity, controlled by the VASP.
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| 4. | “Client Account” means an account at a Third-Party Bank which—
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| | a. | holds or is established to hold the Client Money of one or more clients; and |
| | b. | is maintained in the name of the VASP.
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| 5. | “Third-Party Bank” means the bank with which a Client Account is maintained.
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