What “ADGM custody” actually protects
Anyone can write “secure” on a website. Not everyone can point to a Financial Services Permission number. Changer.ae's FSRA permission 220142 covers three regulated activities: Providing Custody, Arranging Deals in Investments, and Dealing in Investments as Agent — in virtual assets and stablecoins. Here is what those obligations don't-just-on-paper entail.
1 · “Providing Custody” is a licensed activity, not a feature
Under the Financial Services and Markets Regulations 2015 (FSMR, Schedule 1 Paragraph 43, taking custody of client money or assets) — that legal constraint is what “Providing Custody” names. The permission binds the custodian to how client property is received, controlled, and released. Compare that to a wallet provider where “custody” is a UI label — the label around the asset here represents a regulator.
2 · Client assets are treated as client property
Under COBS Chapter 15 (the FSRA's Client Assets & Safe Custody rules): assets held for clients are held on trust-like footing as client property, not as an intercompany receivable or a trading book. Practical consequences:
- Segregation — your assets are Changer.ae's clients', not Changer.ae's. Company assets in the same wallets would violate the rulebook, so they don't exist there.
- Omnibus wallets — your coins are pooled with other clients' for operational efficiency, but individual claims remain per-client and reconciled.
- Daily reconciliation — holdings are reconciled against client positions every day; with near-real-time statements on top.
3 · Jurisdiction matters (and yours is ADGM)
Changer.ae holds client assets inside the ADGM — meaning market practices, insolvency regime, and the supervisory power of the FSRA apply to the custody operation itself. If our operations ever moved client assets outside the ADGM, clients would receive disclosure by email first, including how those regimes differ.
4 · The rest of the permission engine
- Arranging Deals in Investments: we solicitly receivers exchange for quotes among Approved Liquidity Providers, transmit your order, settle — never into our own book.
- Dealing in Investments as Agent: we act as your agent for execution with the Approved Liquidity Provider — same prohibition on principal risk; best-execution duties apply to aspects outside your specific instruction.
- Classification: you are classified Retail or Professional under COBS, with notice, reclassification rights and scheduled checks — protections differ on classification deliberately.
- Financial crime defenses: AML/CFT procedures, customer due diligence, screening, a right to freeze on suspicion and regulator-approved reporting duties.
5 · What regulation does not do
Regulation does not repeal market reality: assets can still be volatile and remain, notably, virtual assets — not legal tender; stablecoins can de-peg; an FSRA-approved asset can be delisted. What regulation does do is guarantee that when these events occur,a specific rulebook, a supervisory authority, and a dispute path apply — instead of a terms-of-service clause.
