Regulatory Alerts2020-02-21
DLT Framework — Guidance Note 5 Protection of Client Assets
The Gibraltar Financial Services Commission issued Guidance Note 5 to define the operational, technical, and organizational standards required for Distributed Ledger Technology Providers to protect client assets and money. The document mandates strict segregation of customer funds, robust systems of control including multi-factor authentication and regular stress-testing, and specific protocols for private key management such as cold storage and multi-signature arrangements. Additionally, providers must implement frequent reconciliation processes, maintain comprehensive audit trails for at least five years, and ensure naming schemas allow for asset control during intervention scenarios.
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