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C. Disclosure, Reporting and Audit Requirements

1. Proper record keeping.
  a. VASPs shall keep proper and up-to-date records regarding—
    i. the receipt and payment of Client Money and in and out of Client Accounts; and
    ii. movements of Client Money within internal systems to enable the reconciliation of any differences in balances or positions of Client Money.
  b. VASPs shall have appropriate procedures for identifying Client Money received. The procedures should cover Client Money received through all means, including electronically or via agents of the VASP [e.g. banks, payment processors].
  c. VASPs may be requested to demonstrate evidence of above records upon VARA’s request.
2. Client reporting.
  a. VASPs must send or otherwise make available a statement to clients at least monthly, or as agreed with the client, which shall include—
    i. the client’s total Client Money balances held by the VASP;
    ii. the amount, date and value of each credit and debit paid into and out of the account since the previous statement; and
    iii. any interest earned or charged on the Client Account since the previous statement.
  b. The statement sent to the client must be prepared within twenty-five [25] calendar days of the statement date.