Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures. The analysis needs the actual control model.[1]
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]
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.
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 practiceReferences
Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.
- 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.
- Ape Law: ADGM VASP licensing Ape Law · Service description
Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
- 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.