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D. Insurance

1. VASPs must hold and maintain the following types of insurance adequate to the size and complexity of the business and VA Activities and in the manner specified by VARA in its Licence [Insurance]—
  a. professional indemnity insurance;
  b. directors’ and officers’ insurance;
  c. commercial crime insurance or similar types of insurance for all Virtual Assets stored in hot wallets; and
  d. any other type of insurance as assessed by VARA to be appropriate for a VASP’s business and VA Activities and stipulated in the conditions to its Licence.
2. All Insurance must be held and maintained with a regulated insurer.
3. Insurance may be held in the name of another Entity in the VASP’s Group, provided that the relevant policy—
  a. explicitly states the VASP as an insured party; and
  b. states the level of cover applicable to the VASP.
4. VARA may apply discretion during the licensing process if, for proven and demonstrated reasons the requirements in Rule VI.D.1 of this Company Rulebook cannot be met, provided that VASPs shall be required to protect against the risks that such Insurance is designed to cover through other means which will be specified by VARA as a condition of a Licence.