# Custody

Canonical: https://abudhabidigitalassetlaw.com/custody/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

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.[\[1\]](https://abudhabidigitalassetlaw.com/custody/#ref-adgm)

## 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.[\[1\]](https://abudhabidigitalassetlaw.com/custody/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Control | Who can initiate, approve or recover asset movements? |
| Records | How do account balances relate to customer entitlements? |
| Failure | How are access, continuity and claims handled? |

## Put it into practice

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

**Useful output**: A custody responsibility matrix and evidence-backed procedures.

## 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.[\[2\]](https://abudhabidigitalassetlaw.com/custody/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/custody/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Operating models — **Exchange →** — An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Structure & activities — **Tokenized assets →** — A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Operating models — **SPV →** — An SPV is a vehicle chosen for a defined structural purpose.](https://abudhabidigitalassetlaw.com/spv/)

## 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 ↗](https://www.adgm.com/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 ↗](https://ape.law/services/adgm-vasp-license) — 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 ↗](https://ape.law/victoria-wells) — 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.](https://abudhabidigitalassetlaw.com/sources/)