Client Assets Safeguarding and Segregation Policy

Last updated: July 1, 2025

1. Introduction

At Veli UAB (“Veli”, “we”, or “the Company”), the protection of our customers’ assets is a fundamental priority.

We are fully committed to ensuring that all funds and crypto-assets entrusted to us are safeguarded, segregated, and protected in accordance with European Union Regulation (EU) 2023/1114 and the Law on Cryptocurrency Asset Markets of the Republic of Lithuania.

This policy explains how we keep client assets separate from the Company’s own funds, how we manage and monitor those assets daily, and how we ensure that in the unlikely event of insolvency, our clients’ interests remain fully protected.

2. Purpose and Objectives

The purpose of this policy is to ensure the integrity, security, and transparency of all customer assets held by Veli.

Its main objectives are to:

  • Guarantee that client funds and crypto-assets are never mixed with the Company’s operational funds;
  • Maintain accurate, real-time records of all client balances;
  • Protect clients’ rights in the event of insolvency;
  • Meet the highest standards of safeguarding and segregation set by EU and Lithuanian law; and
  • Provide customers with clear, accessible information about how their assets are protected.

 

This policy applies to all clients and all forms of assets held with Veli, including fiat currencies and digital assets.

3. How We Safeguard Client Assets

3.1 Segregation of Funds

All client funds are held in dedicated safeguarding accounts with reputable credit institutions or central banks located within the European Economic Area (EEA).

These accounts are separate from Veli’s operational and treasury accounts and are designated solely for client fund storage.

Client funds are never used for Company operations, expenses, investments, or any other business activity.

All deposits received from clients are transferred to safeguarding accounts no later than the end of the following business day.

 

3.2 Segregation of Crypto-Assets

Client crypto-assets are held in segregated wallets that are distinct from Veli’s own corporate wallets.

Each client’s holdings are recorded separately in our internal ledger to maintain a clear and auditable record of ownership.

Where omnibus wallets (shared storage) are used, we ensure precise internal accounting and reconciliation to identify each client’s exact share at any given time.

Cold-storage and multi-signature wallets are implemented for additional protection.

3.3 Prohibition of Use

Client assets — whether fiat or crypto — are never used by Veli for trading, lending, hedging, or investment purposes. They remain the exclusive property of the client at all times.

4. Client Onboarding and Account Setup

To ensure secure safeguarding, the protection of client assets begins during the onboarding process.

During registration, clients are verified through our Know Your Customer (KYC) procedures in accordance with our AML/CTF Policy.

Only verified clients may deposit or hold assets with Veli.

Each verified customer is assigned a unique client ledger in our internal systems, ensuring transparent asset tracking from the moment of deposit.

Clients are informed during onboarding about how their assets are safeguarded and how segregated accounts operate.

5. Reconciliation and Daily Controls

Veli performs daily reconciliations of all client funds and crypto-assets.

The balances in safeguarding accounts and crypto wallets are matched against our internal ledger records.

Any discrepancy — even minor — is investigated immediately and resolved within the same business day.

Commissions, fees, or other operational funds are removed from safeguarding accounts by the end of each business day to maintain full segregation.

These reconciliations ensure accuracy, transparency, and the continued protection of client assets.

6. Transparency and Client Communication

Veli believes in full transparency regarding the protection of client assets.

We provide clear and accessible information to all customers about:

  • How their assets are held and safeguarded;
  • The difference between Company funds and client funds;
  • How reconciliation and audits are performed; and
  • What rights clients have if the Company becomes insolvent.

 

Information is made available in our Terms of Service, Policies, and Help Center, written in straightforward language to ensure ease of understanding.

7. Audit and Record-Keeping

Veli conducts internal and external audits at least annually to verify compliance with all safeguarding and segregation requirements.

Detailed records of client balances, deposits, withdrawals, and transactions are maintained securely and are available for inspection by auditors and regulators.

Audit findings are reported to senior management, and corrective measures are implemented promptly where necessary.

All records are maintained in accordance with legal retention requirements and are protected under the General Data Protection Regulation (GDPR).

8. Risk Management and Security Controls

Protecting client assets also means minimizing operational, cybersecurity, and counterparty risks.

8.1 Operational and Cybersecurity Protections

Advanced encryption, multi-factor authentication, and cold storage solutions safeguard clients’ crypto-assets.

Regular penetration tests and security audits are conducted to identify and mitigate vulnerabilities.

Only authorized personnel have access to client asset systems, under strict internal controls and segregation of duties.

 

8.2 Counterparty and Custodian Risk

Veli uses only reliable, regulated financial institutions and custodians within the EEA to hold client assets.

All counterparties are subject to due diligence, ongoing monitoring, and risk assessment to ensure their continued reliability and compliance.

 

8.3 Continuous Risk Assessment

Regular risk reviews and stress tests are carried out to ensure the resilience of our safeguarding arrangements under various scenarios.

The Risk Management and Compliance functions jointly oversee the assessment of all operational and custodial risks.

9. Procedure in the Event of Insolvency

In the unlikely event that Veli becomes insolvent:

  • Client assets remain segregated and do not form part of the Company’s own assets or creditor pool.
  • Detailed and up-to-date records will allow for a prompt and transparent return of funds and crypto-assets to clients.
  • Clients will be notified of the process and their rights under applicable law.
  • Independent administrators or regulators may oversee the distribution of safeguarded assets to ensure fairness and compliance.

 

This ensures that clients retain ownership and priority rights over their funds and crypto-assets.

10. Contact Information

For questions or concerns regarding how your assets are protected, please contact our Compliance Team:

compliance@veli.io