| 1. | “Client VAs” means all Virtual Assets owned by a VASP’s client which are 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. | Virtual Assets 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 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; |
| | b. | held in an account or VA Wallet in the name of the VASP; |
| | 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 |
| | d. | the private keys and/or seed phrase of the VA Wallet are held or controlled by the VASP.
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