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:
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:
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 are never treated as Company property and are not used for:
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:
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:
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:
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:
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:
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:
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:
Questions regarding custody services may be directed to:
NOAH LV SIA
Email: support@noah.com
Website: noah.com