Custody Policy

Client-Facing Custody Policy Summary

1. PURPOSE AND SCOPE

1.1 Purpose

Noah LV SIA is a crypto-asset service provider authorised (or, if submitted pre-authorisation, applying for authorisation) under Regulation (EU) 2023/1114 (MiCA) to provide crypto-asset services, including custody and administration of crypto-assets on behalf of clients.

This Client-Facing Custody Policy Summary explains how Noah LV SIA ("Noah", "we", "our" or "the Company") safeguards crypto-assets held on behalf of clients when providing crypto-asset custody and administration services.

Our custody arrangements are designed to comply with Article 75 of Regulation (EU) 2023/1114 (MiCA) and applicable Latvian law. This summary explains how we hold client assets, protect them against operational and cybersecurity risks, maintain accurate records, and enable clients to exercise their rights.

This summary does not replace the full Crypto-Asset Custody and Administration Policy, which is available free of charge upon request.

1.2 Scope

This summary applies to all clients using NOAH's crypto-asset custody and administration services.

It covers:

  • crypto-assets held in custody by NOAH;
  • the recording and administration of client entitlements;
  • safeguarding arrangements for client fiat funds pending execution where applicable;
  • security measures protecting client assets;
  • client reporting and statements; and
  • client rights in the event of operational disruption or insolvency.

2. HOW WE HOLD YOUR ASSETS

NOAH operates a custody model that combines secure blockchain wallets with an Internal Ledger.

Client Custody Wallets

Client crypto-assets are generally held in pooled Client Custody Wallets (CCWs) secured using Multi-Party Computation (MPC) technology.

Although multiple clients' crypto-assets may be held within the same blockchain wallet, each client's ownership is individually recorded within NOAH's Internal Ledger and register of positions.

Internal Ledger

The Internal Ledger is the official record of each client's entitlement.

It records:

  • crypto-assets held for each client;
  • deposits and withdrawals;
  • transfers;
  • protocol-related events;
  • associated rights (where applicable); and
  • transaction history.

The aggregate of all client balances recorded in the Internal Ledger is fully backed by corresponding crypto-assets held in custody wallets.

3. SEGREGATION OF CLIENT ASSETS

NOAH maintains clear segregation between:

  • client crypto-assets;
  • Company-owned crypto-assets;
  • operational wallets; and
  • Company treasury assets.

Client crypto-assets are never treated as Company property and are not used for:

  • Company operating expenses;
  • proprietary trading;
  • lending;
  • collateralisation; or
  • any purpose other than providing custody and related services.

Company-owned crypto-assets used for liquidity and transaction settlement are held separately within dedicated System Funding Wallets.

4. FIAT FUNDS

The treatment of fiat funds depends on how your transaction is funded.

Bank Transfers (SEPA)

Where a SEPA transfer is received by our electronic money institution or payment service provider and remains subject to compliance or operational checks before settlement, the funds remain safeguarded by that provider and are not yet received by NOAH.

If NOAH receives fiat funds before execution of a crypto-asset transaction, those funds are treated as client funds pending execution and are safeguarded in segregated safeguarding accounts maintained with authorised banking partners.

These safeguarded balances are reconciled daily.

Card Payments

For card purchases of crypto-assets, NOAH generally does not receive or hold client fiat funds.

Card payments are processed directly through regulated payment service providers.

Only where NOAH temporarily receives client fiat funds before transaction execution will those funds be safeguarded in accordance with applicable legal requirements.

5. SECURITY OF CLIENT ASSETS

NOAH implements multiple layers of technical and organisational security designed to protect client assets.

These include:

  • Multi-Party Computation (MPC) wallet infrastructure;
  • multi-level transaction approvals;
  • role-based access controls;
  • multi-factor authentication;
  • cryptographic key protection;
  • secure cloud infrastructure;
  • continuous monitoring of custody systems;
  • tamper-resistant audit logging;
  • daily reconciliations between blockchain balances and Internal Ledger records; and
  • incident response and business continuity procedures.

Access to systems managing client assets is restricted to authorised personnel only.

6. MONITORING AND RECORD KEEPING

NOAH maintains an individual register of positions for every client.

The register records:

  • crypto-assets held;
  • transaction history;
  • associated rights;
  • protocol events affecting holdings;
  • blockchain transaction references; and
  • current balances.

Our records are reconciled daily against blockchain balances and retained in accordance with applicable legal and regulatory requirements.

7. YOUR RIGHTS

Clients remain beneficially entitled to the crypto-assets held on their behalf.

Where supported by the relevant blockchain protocol, NOAH will administer rights associated with crypto-assets, including where applicable:

  • protocol upgrades;
  • token distributions;
  • forks;
  • staking-related entitlements; and
  • governance rights,

subject to the relevant protocol, technical feasibility and our custody arrangements.

Clients may request a statement of their holdings at any time.

NOAH also provides periodic statements through secure electronic channels.

8. COMPLIANCE REVIEWS AND TRANSACTION RESTRICTIONS

Certain transactions may be delayed or temporarily restricted where required by law or to protect clients.

This may occur where:

  • identity verification is incomplete;
  • anti-money laundering or sanctions screening is required;
  • Travel Rule information is incomplete;
  • fraud prevention measures are being applied; or
  • operational or cybersecurity concerns arise.

Where client assets are temporarily restricted, they remain recorded in the client's register of positions and cannot be transferred until the relevant review has been completed.

9. THIRD-PARTY SERVICE PROVIDERS

NOAH may use specialist third-party providers to support custody infrastructure, cloud hosting, wallet technology or key management.

Before engaging any provider, NOAH performs due diligence covering:

  • regulatory status;
  • operational resilience;
  • information security;
  • business continuity;
  • financial stability; and
  • contractual safeguards.

Where third-party providers are used, NOAH remains responsible for safeguarding client assets and complying with applicable regulatory obligations.

10. IF SOMETHING GOES WRONG

NOAH maintains incident response procedures covering operational failures, cybersecurity events and custody-related incidents.

Where an incident affects client crypto-assets, we will:

  • investigate the incident promptly;
  • take measures to contain and remediate the issue;
  • notify affected clients where required by law;
  • report to competent authorities where applicable; and
  • provide compensation where required under applicable law and our contractual obligations.

11. IF NOAH BECOMES INSOLVENT

Client crypto-assets are held separately from NOAH's own assets.

They are recorded individually within NOAH's Internal Ledger and register of positions and are intended not to form part of NOAH's estate in the event of insolvency, subject to applicable insolvency law.

NOAH maintains procedures designed to enable the prompt return of client crypto-assets where required.

12. FURTHER INFORMATION

Clients may request, free of charge:

  • the full Crypto-Asset Custody and Administration Policy;
  • statements of crypto-assets held in custody;
  • additional information regarding custody arrangements; or
  • information about any material changes to our custody arrangements.

Questions regarding custody services may be directed to:

NOAH LV SIA

Email: support@noah.com

Website: noah.com

Custody Policy