Terms & Policies

Summary of the Client Asset Safeguarding Policy and Plan

1. Introduction

1.1 Purpose and scope


This Policy is designed to ensure compliance with the following legal and regulatory requirements.


MiCA (EU Regulation 2023/1114), specifically Articles 68 (Organisational Requirements), 70 (Safekeeping of Client Assets), 73 (Outsourcing), and 75 (Custody and Administration of Crypto-Assets).


RDAEL recognises the critical importance of safeguarding and protecting client assets in its operating model. For the purposes of this policy, references to client assets refer to crypto assets. RDAEL does not process or hold any fiat for or on behalf of its clients. The Client Asset Safeguarding Policy and Plan (the “Policy’) seeks to address the below areas:

  • To outline RDAEL’s business model and related risks in respect of the safeguarding of client assets and the controls in place to mitigate these;
  • To demonstrate how RDAEL’s systems and controls meet the principles of the client asset regime;
  • To enable the Board of RDAEL (the “Board”) to document and monitor material changes to RDAEL’s business model, changes to controls and processes and any changes regarding the associated risks to safeguarding client assets; and
  • To make information readily available to assist in the prompt distribution of client assets, particularly in the event of RDAEL’s insolvency.


RDAEL’s operating model in relation to crypto assets is based on operating an omnibus wallet with third party exchanges and custodians.


1.2 Authorisation

RDAEL obtained its authorisation and acts as a crypto asset service provider under the EU Regulation 2023/1114 on markets in crypto assets (“MiCA”) since 20 October 2025. Under its license, it is authorised to the following services:

  • providing custody and administration of crypto-assets on behalf of clients;
  • operation of a trading platform for crypt-assets;
  • exchange of crypto-assets for funds;
  • exchange of crypto-assets for other crypto-assets;
  • placing of crypto-assets; and
  • providing transfer services for crypto-assets on behalf of clients.


For the purposes of this Policy, ‘providing custody and administration of crypto-assets on behalf of clients’ means the safekeeping or controlling, on behalf of clients, of crypto-assets or of the means of access to such crypto-assets, where applicable in the form of private cryptographic keys.


The scope of RDAEL’s services related to safeguarding (custody) of the crypto assets includes:

  • Making settlements of executed orders received from clients;
  • Processing certain actions (e.g. changes in response to a fork event);
  • Recording and accounting of the crypto assets in the omnibus wallets;
  • Providing statements of the crypto asset wallets and other reports to clients and/or to authorities (e.g. the Cyprus Securities and Exchange Commission).


2. Safeguarding of clients’ crypto assets


2.1 General requirements


RDAEL’s safeguarding arrangements are designed to ensure that, at all times, client assets are segregated at the entity level, in line with CySEC’s requirements and MiCA Art. 70.


RDAEL shall take adequate measures to protect and safeguard the assets belonging to its clients, including:

  • Keep records and accounts in a way that RDAEL is capable, at any time and without delay, to distinguish the assets held for one client from the assets held for any other client and from the assets of RDAEL;
  • Maintain records and accounts in a way that ensures their accuracy, and their correspondence to the assets held for the clients, and in a way that such records and accounts can be used as an audit trail;
  • Conduct monthly reconciliations between the internal information, on total client balances to those of third parties by whom assets are held;
  • Take necessary steps to ensure that assets of the clients, deposited with a third party, are identifiable separately from the assets belonging to RDAEL and to that third party and have the same level of protection as in RDAEL in accordance with this Policy; and
  • Take relevant organisational measures to minimise the risk of the loss or diminution of the assets belonging to the client, or of rights in connection with those crypto assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence.


2.2 Separation and segregation of clients assets


Assets belonging to RDAEL’s clients are kept separate from:

  • the assets belonging to RDAEL; and
  • the assets belonging to clients of other entities within the Revolut group, with certain exceptions described in this Policy.


Assets belonging to RDAEL’s clients are held exclusively within RDAEL’s dedicated Fireblocks workspaces and MiCA licensed custody venues, ensuring they are strictly segregated from both RDAEL’s proprietary assets and the client assets of other Revolut Group entities. The only exceptions to the latter are specific assets frozen for financial crime compliance or legacy positions undergoing phased migration, all of which remain clearly ledgered and protected under RDAEL’s safeguarding framework.

RDAEL aims to maintain a 1:1 backing of client liabilities as close as possible within these dedicated environments. Given the inherent latency of blockchain settlements and the volatile nature of crypto trading, there may be short periods during active rebalancing windows during which assets are in transit between entities, resulting in temporary mismatches between the assets held in RDAEL-designated wallets and its corresponding client liabilities; however, RDAEL employs automated “sweeps” to minimise such mismatches and to ensure that no unauthorised or prolonged commingling occurs.

RDAEL shall inform the clients via T&C or otherwise, that RDAEL may hold the assets belonging to a client:

  • in an individual user wallet; or
  • together with the assets belonging to other client(s) in an omnibus wallet.


Where RDAEL keeps the clients’ assets in an omnibus wallet or in a wallet opened in the name of RDAEL, then it shall always keep separate records of the crypto assets belonging to each client.

RDAEL may deposit crypto assets of the clients into one or more of the following wallets: (a) self custody wallets, (b) hot wallets, and (c) cold wallets. This applies to RDAEL’s Retail and Business clients opening a crypto account in the Revolut App and/or opening an account in the Revolut X trading platform.


Self Custody wallets


This encompasses the crypto assets RDAEL holds with Fireblocks which is a Multi Party Computation (MPC) wallet, for which RDAEL maintains a direct agreement with Fireblocks. Under this set-up, RDAEL holds the majority of the components of the private keys. This solution is largely used to facilitate Remittances, Staking, moving crypto assets between exchanges and cold storage.

Fireblocks is a provider of the relevant IT infrastructure and as such does not need to be licensed under MiCA as it does not provide any services of custody and administration of crypto-assets on behalf of clients.


Hot Wallets


This encompasses the crypto assets RDAEL holds with Fireblocks and third-party exchanges. A hot wallet is defined as a wallet that has active internet connectivity and where the legal owner or trustee of the crypto assets (i.e. RDAEL) does not own the private keys. While it is less secure than a cold wallet solution, it allows for immediate access to the crypto assets to facilitate trading orders and therefore hot wallets are used to facilitate buy and sell orders received from RDAEL clients.

For RDAEL to be able to hold clients’ crypto assets in hot wallets with third-party exchanges, such third-party exchanges need to be licensed under MiCA.


Cold Wallets


This encompasses the crypto assets RDAEL holds in cold storage. A cold wallet is defined as a wallet that has no internet connection. Such wallets are utilised for enhanced security as they are offline or air-gapped, making them significantly less prone to cyber attacks given the lack of a permanent internet connection.

In order to leverage these crypto assets and facilitate clients’ buy and sell orders, crypto assets on cold wallets first need to be moved to a hot wallet. Given the high-security nature of moving funds from cold custody to hot wallets, RDAEL enforces a strict multi-signature quorum. This requires multiple independent approvals from multiple authorised personnel across Revolut, ensuring that no single individual or admin can unilaterally move funds from cold custody. The majority of client crypto assets are kept in cold wallets.


2.3 Due Diligence of third parties


RDAEL may deposit crypto assets belonging to a client into wallets opened with a third party only if it exercises due skill, prudence and diligence in:

  • selection and appointment of such third party;
  • periodic review of such third party; and
  • periodic review of the arrangements of the holding of the crypto assets.


2.4 Use of crypto assets of clients


RDAEL may not pledge the crypto assets of clients in its own interest or in the interest of a third party. RDAEL may not use crypto-assets belonging to the clients for its own account in any way.


3. Business Model


3.1 Regulated services


RDAEL provides crypto services to clients based within the EEA. RDAEL also provides crypto services to clients based in Switzerland on a reverse solicitation basis. The services listed in section 1.2 above are provided to Retail and Business clients opening a crypto account in the Revolut App and/or opening an account in the Revolut X trading platform, which is operated by RDAEL. Via the Revolut App, RDAEL directly executes trades with customers, by exchanging crypto-assets for funds or other crypto-assets, without routing immediately to an external venue. RDAEL acts as the counterparty to the customer trade and takes full execution risk, determining when and how to hedge open positions. Via Revolut X, RDAEL operates a trading platform allowing its customers to make or take liquidity and trade with each other.


3.2 Omnibus Account


RDAEL maintains a register of positions and is able to determine at any given moment the outstanding balance of its clients’ assets. It is important to note that Revolut Ltd also has access to the wallets where RDAEL clients’ assets are stored, as part of the operational structure that facilitates the execution of client transactions. However, RDAEL retains control and oversight of its clients’ assets. RDAEL has dedicated workspaces for its clients through a direct agreement with Fireblocks. RDAEL exercises positive control over the Transaction Authorization Policy (TAP), which is the transaction signing policy on Fireblocks. No change can take place without the sign off from the owner of the workspaces which is RDAEL's CEO. This means that RDAEL participation is mandatory regarding activities such as the whitelisting of accounts, amending the Transaction Authorization Policy and connecting to new exchange accounts. For any amendments to the TAP, a quorum of at least two approvals is required, meaning no employee is able to act independently or without RDAEL engagement. Quorum can be met by RDAEL employees only.


3.3 Transactional Activity


Clients must first open a bank account with Revolut Bank UAB (RBUAB), as all activities the client undertakes with RDAEL are funded from the balance of the client’s money account with RBUAB. The creation of the client money account and the onboarding process are completed using the Revolut App. Once onboarded into the Revolut App, an RBUAB client can access RDAEL’s crypto services through the Revolut App by clicking on the Crypto widget. The client can then become an RDAEL client by following the crypto onboarding steps, including accepting new terms and conditions relating to RDAEL’s crypto services offering. Once onboarded into the Revolut App, an RBUAB client can also set up a separate crypto account on Revolut X via this link. The client can then become an RDAEL Revolut X client by following the crypto onboarding steps, including accepting new terms and conditions relating to RDAEL’s crypto services offering via Revolut X.

Clients must have sufficient funds on their account (Revolut App and/or Revolut X) in order to facilitate a purchase order. Funds can be debited directly from clients’ bank account held with RBUAB main account in-app.

Clients must have sufficient crypto on their account (Revolut App and/or Revolut X) in order to facilitate a sell order.

Clients can then submit an order (buy or sell) via the Revolut App or Revolut X.


3.4 Custody and Payment of Gas Fees


Custody


As noted in the ‘Omnibus Account’ subsection, RDAEL holds client funds within omnibus treasury vaults (i.e. Fireblocks) and transfers client funds to wallets in order to manage liquidity and rebalance the wallets as to facilitate its crypto services to the clients.


Payment of Gas Fees


When funds are transferred between wallets, transaction fees may be applied to facilitate this movement. Because Revolut holds minimal crypto on its balance sheet, these transaction fees are paid from funds held in the wallet from where the transferred assets are held, i.e. clients’ crypto assets. On an intraday basis, in order to make these balances whole again, internal market making teams will perform a ‘PNL swipe’. This involves buying the same amount of crypto that was used throughout the day to facilitate the movement of funds and crediting the account from where the fees were paid.


By way of example:

Revolut spends 0.0001 BTC on a transaction fee to move funds from an exchange to Fireblocks, with the above amount being debited from the exchange account. This 0.0001 BTC goes into PNL Swipe and, at a later time during the same day, Revolut buys 0.0001 BTC in the market to cover for the fact that it spent that small amount from the exchange account.


3.5 Client Statements


Accurate, complete and up-to-date statements of balances can be viewed by clients via the Revolut App and Revolut X and at any point in time.