VARA VA Management and Investment Services Rulebook (version dated 19 May 2025)chapter by chapter

Part I.A.1-2Part I.A Policies and procedures

VASPs must maintain written policies covering client access and withdrawals including during volatility, client suitability assessment, and Staff competence, and review their effectiveness at least yearly.

Part I.B.1-3Part I.B Public disclosures

VARA-licensed virtual asset management and investment service providers must publicly disclose conflicts of interest, complaints and whistleblowing policies, client asset protection, risk statements, and senior management convictions where lawful.

Part II.A.1-4Part II.A Client suitability

Service providers must offer services only to suitable clients, collect accurate current client information, and keep it for at least eight years.

Part II.B.1Part II.B Staff competency

All virtual asset service provider staff must be knowledgeable, competent and suitably trained, considering qualifications, virtual asset sector experience, and understanding of the VARA framework and industry standards.

Part II.C.1-2Part II.C Verification of information

VASPs must not make misleading, false or deceptive statements, promises or forecasts, and must verify factual information against reliable sources and check its continued accuracy.

Part II.D.1-3Part II.D Impermissible activities

Managed virtual asset providers must not rehypothecate client assets without explicit prior consent and must hold client assets for clients unless the agreement states otherwise.

Part II.E.1-3Part II.E Client reporting and valuation

Providers must issue monthly written statements to clients detailing asset values, transactions, and changes in valuations, with ongoing independent asset valuations.

Part II.F.1 Fees payable from managed assets

A manager may not take any payment or benefit from managed virtual assets unless the client agreement permits it and specifies how fees are calculated, accrued and paid.

Part II.F.2 Fee changes notice

Clients must receive 90 days' written notice for any new fees or fee increases related to managed assets, including the start date.

Part II.G.1Part II.G Marketing of staking rewards

Marketing must not claim that services distribute staking or similar protocol-based rewards unless client payments actually originate directly from those rewards.

Part II.H.1Part II.H Management practices

Virtual asset service providers must act in clients' best interests at all times, considering suitability, price, costs, speed, execution, settlement likelihood, size and custody conditions, while following client instructions.

Part II.I.1-3Part II.I Order transmission

Order-handling procedures must ensure prompt, proper transmission of client orders and bar any undisclosed benefits for routing orders to a particular platform or VASP, and must not misuse client information.

Part II.J.1-2Part II.J Risk management

Virtual asset management firms must regularly monitor and test liquidity and market risk, and have independent third-party audits of risk management and due diligence provided to VARA on request.

Part II.K.1Part II.K Client Agreements

VARA client agreements must describe assets, staking rights, proceeds, withdrawal and termination rights, risks, default consequences, and complaints procedures, with clear client consent to asset use.

Part II.A.3-retRecord Retention — Client information collected for suitability assessment

Client information collected for suitability assessment must be retained for eight years from the date it was collected or last updated.