KNOW THE BASICS
We take looking after your assets very seriously — but here’s the no-jargon version of how we keep your crypto and euros safe and separate from ours.
Introduction
Asset Segregation and Safeguards
Risk Management and Compliance
Policy Updates and Client Communication
Client Assets & Funds Segregation Policy
1. Introduction
At Venga, the protection of your assets is our highest priority. This policy outlines how we safeguard and administer your crypto-assets and fiat funds in full compliance with the Markets in Crypto-Assets Regulation (MiCA) and other applicable EU regulations. This overview summarizes our custody and asset administration framework, including how your assets are stored, monitored, and maintained. It covers key elements such as custodial structures, segregation practices, reconciliation processes, client rights facilitation, departmental responsibilities, and breach management protocols. Our commitment to security is backed by advanced safeguards, including multi- signature wallets, strong encryption standards, and regular independent audits. These are supported by robust internal controls, periodic reconciliation of client holdings, and ongoing oversight of all custody activities to ensure maximum protection and regulatory compliance. This summary highlights the core principles of our Custody Policy to ensure clients have clear visibility into how their assets are protected and managed.
We take looking after your assets very seriously — but here’s the no-jargon version of how we keep your crypto and euros safe and separate from ours.
2. Asset Segregation and Safeguards
At Venga, client assets are strictly segregated from the company’s own holdings. This core principle ensures client entitlements remain protected and fully traceable at all times, in line with regulatory requirements and best practices. Client crypto-assets are held in dedicated wallets, typically omnibus wallets, which may combine assets from multiple clients but never include company funds. Although these wallets are not individually labeled on-chain or by custodians, Venga maintains a comprehensive internal register for each client. This register records the type, amount, value, and location of each client’s assets, as well as any movements affecting ownership. Fiat funds are managed through licensed third-party providers (¨Fiat Custodians¨) authorized under applicable financial laws. These funds are stored in segregated accounts that are separate from the company’s operational accounts. Like with crypto-assets, a client-by-client internal ledger is used to monitor fiat balances and transactions. Only reputable distributed ledger (DLT) providers and custodians with strong safeguards are used to manage custody. Across both asset types, regular reconciliations are performed against blockchain records, custodian data, and internal systems to ensure accuracy, transparency, and ongoing protection.
Our Golden Rule: Your stuff is not our stuff
- Your assets are kept completely separate from Venga’s own funds.
- For crypto: we use special wallets (sometimes shared between clients, but never with us). We track exactly what’s yours in our internal register — type, amount, value, and where it’s stored.
- For fiat: we use licensed third-party banks (a.k.a. “Fiat Custodians”) and separate accounts just for client money.
3. Risk Management and Compliance
Venga maintains a robust risk management framework to ensure the integrity of asset segregation and compliance with regulatory standards. In the event of any issue that may affect the proper segregation of client assets, such as technical failures or third-party errors, a clear internal process is followed to promptly identify, report, investigate, and resolve the matter. Significant incidents are escalated to senior management and thoroughly documented. To strengthen operational resilience, all staff involved in the custody, handling, or oversight of client assets receive mandatory training at least once per year. This training is tailored to each employee’s role and updated as needed to reflect legal, regulatory, or procedural changes, ensuring a consistent understanding of internal controls and segregation requirements. In addition, Venga’s Internal Audit team conducts an independent review of asset segregation practices at least annually. These audits help validate the effectiveness of controls, identify areas for improvement, and ensure ongoing alignment with applicable regulations and internal policies.
How we keep it safe
- Reputable blockchain and custody partners only — no dodgy middlemen.
- Regular checks and reconciliations to make sure our records, blockchain, and custodian data all match up.
- Multi-signature wallets, strong encryption, and regular independent audits.
4. Policy Updates and Client Communication
This policy is reviewed and updated regularly by Venga’s Compliance and Risk teams to ensure it remains aligned with evolving regulations and internal operational practices. Any material changes that may impact client rights or the safeguarding of assets are communicated promptly and through appropriate channels. Clients are encouraged to reach out to our support team with any questions regarding the handling of their assets or related procedures. Additional detailscan always be found in the full Custody Policy available on our website.
If something goes wrong
- We have a playbook for dealing with issues like tech glitches or third-party mistakes.
- Problems are reported fast, escalated to senior management, and fully documented.
- Staff who handle your assets get yearly training to stay sharp (and compliant).
- Our Internal Audit team checks our processes at least once a year.