Last updated: 20/08/2026
1. Overview
Scintilla Network FZE (“Scintilla”) is committed to safeguarding client assets with the highest standards of security, transparency, and regulatory compliance. We comply with the Dubai Virtual Assets Regulatory Authority (VARA) Custody Rulebook and ensure that all client Virtual Assets are held securely, segregated from Scintilla’s own assets, and protected against misuse.
2. Use of Regulated Custodians
Scintilla does not self-custody client Virtual Assets. Instead, we partner exclusively with VARA-licensed and regulated custodians.
• Our primary custodian is Hex Trust, a VARA-regulated Virtual Asset Custodian.
• Custodians maintain robust safekeeping processes, including multi-signature wallets, cold storage, and insurance coverage.
• All custodians are subject to independent audits and regulatory oversight.
3. Segregation of Client Assets
• Client assets are segregated from Scintilla’s own operational funds.
• Scintilla does not rehypothecate, pledge, or otherwise use client assets for its own account.
• Each client’s holdings are recorded on our systems and reconciled daily with the custodian’s records.
4. Protection of Ownership Rights
• Clients remain the beneficial owners of their Virtual Assets at all times.
• Custodian arrangements are structured to ensure that client ownership rights are preserved, even in the event of Scintilla’s insolvency.
• Clients can request confirmation of holdings at any time through Scintilla’s client services team.
5. Insurance & Safeguards
• Regulated custodians may provide insurance against theft, cyberattacks, or operational loss.
• Scintilla performs due diligence to ensure adequate insurance and security safeguards are in place at all times.
• Clients will be notified of the scope and limitations of custodian insurance coverage.
6. AML / CFT Monitoring
• Client assets are subject to continuous monitoring to prevent money laundering, terrorist financing, or sanctions evasion.
• Custody arrangements include transaction screening and suspicious activity reporting, in line with VARA’s AML Rulebook.
7. Disclosures for Token Issuances
For Virtual Asset issuances (if applicable) managed by Scintilla:
• Issuance tokens will also be safeguarded with VARA-licensed custodians.
• Whitepapers will specify custody arrangements, including details of lock-ups, vesting schedules, or redemption processes.
• Scintilla will disclose how issuance-related assets are separated from exchange or broker-dealer holdings.
8. Client Rights and Inquiries
Clients may request at any time:
• Confirmation of asset balances held in custody;
• Details of custodian arrangements;
• Copies of Scintilla’s custody and safekeeping policies.
Requests may be submitted by to:
Email: compliance@scintillanetwork.com
Phone: +971047700495
9. Our Commitment
Scintilla is committed to:
• Full compliance with the VARA Custody and Issuance Rulebooks;
• Maintaining the highest standards of asset protection;
• Providing clear, timely, and accurate disclosures to clients and investors
