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Summary of the Crypto-Assets Custody Policy

The Wirex Crypto Assets Custody Policy (the “Policy”) explains how Wirex Europe sp z.o.o. and Wirex Digital Services s.r.l. (referred to as "Wirex" and "Our") protects your crypto-assets. It follows the requirements set by European and Italian regulators including the Markets in Crypto Assets Regulation (MiCA). Its purpose is to safeguard your crypto-assets and to support a relationship of trust based on security transparency and accountability.  

The policy sets out the measures Wirex takes to protect your assets. This includes keeping our clients' crypto-assets separate from our own assets, maintaining strong security controls, ensuring that our staff receive appropriate training, and carrying out regular checks to confirm that all systems are working correctly.  

Before using any crypto-asset services provided by Wirex you must agree to the Wirex General Terms of Service and Crypto-Assets Terms of Service. Those documents explain the services offered, the protections in place, the applicable fees, and the legal framework governing your use of our services.  

Wirex safeguards client assets through our Custodian Technology Provider. Wallets operated through our Custodian Technology Provider strictly separate Wirex corporate assets from client assets and use advanced technology such as encryption and multi-level approval processes. Operations are conducted in separate environments, one dedicated to client assets and one dedicated to Wirex corporate assets.  

No single individual can transfer assets without the necessary approvals. Wirex also uses independent third party which provides access to recovery support in the event of technical issues or exceptional circumstances using secure key backups and recovery procedures.  

Client assets are never mixed with those of Wirex or other clients. If Wirex were ever to stop operating, your assets would remain protected and will be returned to you.   

For operational safety purposes, wallets are organised into three types: 

  • a wallet used for receiving deposits; 

  • a long-term storage wallet; and 

  • a wallet used for processing withdrawals.  

Wirex does not use client crypto assets for its own purposes. Wallets are clearly labelled and segregated, and client assets cannot be lent, invested or used for corporate benefit.  

Additionally, Wirex may engage selected partners to support or facilitate the custody arrangements for stablecoins. 

Wirex keeps accurate and secure records of your crypto assets, including the amounts held, their value and every movement they make in your Wirex account for at least ten years. Daily reconciliations ensure that balances match our internal records, and any differences are investigated and corrected promptly. You may request a detailed statement of your holdings at any time, so that you can monitor your account with clarity and confidence.  

Wirex is not responsible for issues with external infrastructure such as blockchain networks.   

Only authorised staff members may access crypto assets, and their tasks may include viewing transactions, approving transfers, or managing our internal systems.  

All activities are logged onto our systems and our Custodian Technology Provider. Regular reporting is provided to the Finance and Compliance teams to maintain transparency and oversight.  

The Board of Directors is responsible for overall regulatory compliance. The Head of Commercial Finance of the Wirex Group and the Accounting and Administrative Manager of Wirex Digital Services oversee daily reconciliations and address any issues promptly. The Money Laundering Reporting Officer ensures compliance with anti-money laundering and financial crime regulations.  

Furthermore, our employees receive ongoing training in identifying risks and fraud following internal procedures and dealing with incidents. Training is updated regularly to reflect regulatory and technological changes. 

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