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Schedule 1 – VA Activities

VA Activity VA Activity
“Advisory Services”
means offering, providing or agreeing to provide a personal recommendation* to a client, either upon its request, or on the initiative of the Entity providing the recommendation, in respect of one or more actions or transactions relating to any Virtual Assets.
*When providing a personal recommendation, the Entity providing the recommendation shall consider the following factors at a minimum in respect of each client—
[a] knowledge and experience in investing in Virtual Assets;
[b] investment objectives including, but not limited to, risk tolerance, time horizon and venues through which they can acquire Virtual Assets; and
[c] financial circumstances including, but not limited to, their ability to bear sudden and significant losses or proportion of their net worth invested in Virtual Assets.
“Broker-Dealer Services”
means any of the following—
[a] arranging orders for the purchase and sale of Virtual Assets between two Entities;
[b] soliciting or accepting orders for Virtual Assets and accepting fiat currency, or other Virtual Assets, for such orders;
[c] facilitating the matching of transactions in Virtual Assets between buyers and sellers;
[d] entering into Virtual Asset transactions as a dealer on behalf of the Entity for its own account;
[e] making a market in Virtual Assets using client assets; or
[f] providing placement, distribution or other issuance* related services to clients issuing Virtual Assets.
*As per Regulation II, any Entity in the Emirate that issues a Virtual Asset in the course of a business, must comply with the VA Issuance Rulebook, as may be amended from time to time.
“Category 1 VA issuance” has the meaning ascribed to it in the VA Issuance Rulebook.
“Custody Services”
means safekeeping Virtual Assets for or on behalf of another Entity and acting only on verified instructions from or on behalf of such Entity*.
*All VASPs shall be subject to Rules regarding the storage and custody of clients’ Virtual Assets. Only VASPs which segregate each client’s assets in separate VA Wallets will qualify for a Custody Services Licence.
“Exchange Services”
means any of the following—
[a] conducting an exchange, trade or conversion between Virtual Assets and fiat currency;
[b] conducting an exchange, trade or conversion between one or more Virtual Assets;
[c] matching orders between buyers and sellers and conducting an exchange, trade or conversion between [i] Virtual Assets and fiat currency or [ii] one or more Virtual Assets; or
[d] maintaining an order book in furtherance of [a], [b] or [c] above.
“Lending and Borrowing Services” means carrying out a contract under which a Virtual Asset shall be transferred or lent from one or more parties [the Lender[s]] to one or more other parties [the Borrower[s]] where the Borrower[s] shall commit to return the same, at the request of the Lender[s], at any time either during or at the end of the period agreed upon.
“VA Management and Investment Services”
means acting on behalf of an Entity as an agent, or fiduciary, or otherwise taking responsibility for the management, administration or disposition of that Entity’s Virtual Assets.
Examples may include, but shall not be limited to—
[a] investment management services or otherwise managing Virtual Assets; and
[b] taking responsibility for the staking of Virtual Assets for the purposes of earning fees or other amounts paid to validators and/or node operators of a proof-of-stake Distributed Ledger Technology.
“VA Transfer and Settlement Services” means the transmission or transfer, and/or settlement of Virtual Assets from one Entity to another Entity or from one Entity to another VA Wallet, address or location.