Purpose
Ensure the highest level of protection and transparency by enforcing strict segregation between client assets and the company’s own funds and holdings. Keep client money and virtual assets separate, identifiable, clearly labeled and matched to client entitlements, safeguarding them from misuse, misallocation, or loss in the event of financial distress or insolvency.
Scope
Applies to all Client Accounts, Client VA Wallets, and any corporate accounts or wallets used in connection with client asset activities.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Maintain designated Client Account bank accounts | Used exclusively for holding client money, separate from Bitkaya’s own funds. Client Accounts must be titled “Client Account”. | Account inventory with “Client Account” labeling |
| 2 | Maintain designated Client VA Wallets | Used exclusively for holding client virtual assets, separate from Bitkaya’s own virtual assets. Labeled “Client VA Wallet” in Bitkaya’s records. | Wallet inventory with “Client VA Wallet” labeling |
| 3 | Label each account and wallet consistently | Clear labeling in banking, custody, ledger and reconciliation records and systems. | Account and wallet labeling in records and systems |
| 4 | Place client money into a designated Client Account within three (3) calendar days of receipt | Timely placement to ensure segregation. | Receipt and three-day placement evidence |
| 5 | Do not deposit Bitkaya’s own funds into a Client Account | Except to meet a temporary shortfall under exceptional and documented circumstances. | Exception records for any own-funds deposits |
| 6 | Maintain client virtual-asset holdings on a strict one-to-one basis | Balances in custody always match client entitlements, eliminating shortfall risk and guaranteeing full client access. | One-to-one holding evidence |
| 7 | Prohibit use of one client’s assets for another’s obligations | No use of one client’s money or virtual assets to satisfy another client’s obligations or Bitkaya’s own operational needs. | Segregation and prohibition acknowledgment records |
| 8 | Prohibit lending, staking, or other financial activities using Client VAs | Unless explicit prior client consent is obtained and Bitkaya has appropriate licensing for such activity. | Consent, legal review and licensing evidence |
| 9 | Credit any proceeds from client VAs to the client’s benefit | Includes airdrops, staking rewards, or other network-based distributions. Exceptions only if explicitly agreed in writing. | Proceeds crediting and written exception records |
| 10 | Do not assume ownership rights over client VAs | Only permissible exception: assets placed under trust with clients recognized as ultimate beneficiaries, keeping client VAs legally distinct from Bitkaya’s estate in insolvency. | Beneficial ownership and trust documentation |
| 11 | Escalate any commingling, shortfall, or misallocation immediately | Escalate and restrict affected activity when unclear ownership or misallocation is identified. | Escalation and restriction records |
Records
- Account and wallet inventory with clear “Client Account” and “Client VA Wallet” labeling
- Client entitlement and beneficial ownership records
- Receipt and three-day placement evidence
- One-to-one holding evidence
- Consent, legal review, licensing evidence and exception records for any lending, staking or other use
- Proceeds crediting and written exception records
Relationships
- Policy: POL-SAFU-001 Client Asset Protection and Safeguarding Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-SAFU-002 Ensure Client Assets Are Segregated and Fully Matched
History
- 2026-07-26: Created from sections 2-5 of the approved SAFU Manual.