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A. Policies and Procedures

1. In addition to all other requirements in the Regulations and Rulebooks, VASPs providing Custody Services shall establish, implement and enforce appropriate written internal policies and procedures relating to the following—
  a. the ability of clients to have access to and withdraw their Virtual Assets including, but not limited to, during periods of high uncertainty and/or extreme volatility; and
  b. such other policies or procedures as VARA may require from time to time.
2. VASPs providing Custody Services shall assess and, in any case, at least yearly review the effectiveness of their policies and procedures, and take appropriate measures to address any deficiencies.