Operating models

Custody

Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures.

Reference entryPublished 25 September 2026By Ape Law
Answer in brief

Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures. The analysis needs the actual control model.[1]

01

Understanding the question

Identify wallets, accounts, signers, access controls and reconciliation. State who owes the customer obligations and what happens on provider failure. A technical description without a contractual allocation of responsibility leaves part of the model unexplained.[1]

02

Build the working record

ConsiderationWhat to establish
ControlWho can initiate, approve or recover asset movements?
RecordsHow do account balances relate to customer entitlements?
FailureHow are access, continuity and claims handled?
03

Put it into practice

A recovery key held by a vendor creates a dependency even if the main signing process is operated internally.

Useful outputA custody responsibility matrix and evidence-backed procedures.
04

Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[2][3]

Ape Law’s ADGM licensing practice
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REF

References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

  1. ADGM: Financial Services Regulatory Authority ADGM · Official regulatory source

    Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.

  2. Ape Law: ADGM VASP licensing Ape Law · Service description

    Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.

  3. Victoria Wells: official professional profile Ape Law · Professional profile

    Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. Read the citation method.