Prepared in accordance with the Rules on the Licensing of Crypto-Asset Service Providers, approved by Resolution No. 03-157 of the Board of the Bank of Lithuania of 17 December 2024, point 7.
UTRG UAB is committed to protecting client assets by keeping all client-owned crypto-assets and funds strictly segregated from the Company’s own assets, in full compliance with applicable regulations (such as Article 70 of the EU Markets in Crypto-Assets Regulation). This statement explains how we separate and safeguard your cryptocurrencies and any related funds, ensuring that your assets remain your property under all circumstances. Key measures under our Client Asset and Fund Segregation Policy include:
Separate Crypto-Asset Wallets: All client crypto-assets held by UTRG UAB are kept in secure wallets completely separate from the Company’s wallets. We never commingle client holdings with corporate funds on the blockchain or in our internal ledgers. Each client’s crypto-assets reside in either a uniquely assigned blockchain address or a pooled address used exclusively for clients, in both cases distinct from any UTRG UAB treasury accounts. This ensures that, on the public ledger and in our records, your cryptocurrencies are clearly identified as your property and not UTRG UAB’s assets.
Legal Separation and Insolvency Protection: Client assets are not only operationally separated but also legally segregated. In our accounting, all client crypto-assets and related rights are recorded off-balance sheet as assets held on behalf of clients (i.e. treated as fiduciary assets rather than company property). This means that even in the unlikely event of UTRG UAB’s insolvency, your crypto-assets would remain yours and would not be available to the Company’s creditors. We periodically transfer any earned fees or revenues out of client asset accounts into the Company’s own accounts, so the pooled client assets remain intact and untouched except to fulfil client instructions. Your funds and crypto-assets thus stay protected and separate from UTRG UAB’s financial obligations at all times.
Daily Reconciliation and Safeguards: UTRG UAB uses rigorous internal controls to enforce segregation. We perform daily reconciliations between the on-chain balances of client wallets and our internal records to ensure they match exactly. Any discrepancy, no matter how small, triggers an immediate investigation by our Compliance team and operations management. In addition, we implement extra safeguards: for example, where feasible, we maintain insurance coverage to protect against losses of client crypto-assets due to theft or cybersecurity breaches. We also have robust contingency plans – encrypted backups of critical wallet keys and data are stored offsite, and a detailed incident response and disaster recovery procedure is in place. In a serious incident (e.g. a security breach), we can suspend movements, secure assets, and activate plans to maintain custody services or promptly return assets to clients if needed. These measures ensure that even under adverse conditions, segregated client assets remain safe and accounted for.
Handling of Fiat Funds in Crypto Transactions: UTRG UAB’s business model is designed so that we do not hold onto client fiat funds are never held longer than necessary during crypto exchange transactions. When you purchase cryptocurrency on our platform with fiat money (e.g. via credit card or bank transfer), your payment is processed by our integrated regulated payment service providers, not by UTRG UAB directly. We deliver the purchased crypto-asset to your wallet immediately upon payment authorisation. The fiat funds are then settled from the external payment processor to UTRG UAB, at which point We treat these funds as the Company’s revenue revenue from the sale (since you have already received your crypto) rather than client funds. In other words, there is no prolonged holding of fiat on your behalf that would require segregation – the transaction is essentially instantaneous from your perspective. Nonetheless, UTRG UAB uses dedicated bank accounts for these incoming fiat payments and conducts meticulous reconciliation of each transaction to ensure accuracy. We track every exchange order and its corresponding fiat flow so that any delay or discrepancy (for example, a payment that fails after crypto was delivered) is promptly flagged and addressed. This process guarantees transparency and integrity for all fiat-to-crypto exchanges without requiring the pooling of client fiat funds.
Safeguarding Client Funds in the Utorg Card Program: If UTRG UAB does hold fiat funds on your behalf for any service, those funds are strictly segregated and safeguarded. For example, our crypto-linked Utorg Card service (which allows you to spend the value of your crypto via a payment card) uses a special pooled account, known as an omnibus account, that holds the combined fiat value of all clients’ card balances separately from the Company’s assets. This omnibus fiat account is opened with a licensed financial institution and is used solely to store customers’ card funds. It is completely separate from UTRG UAB’s operational accounts, and the Company does not use any funds in this account for corporate expenses, investments, or any purpose other than processing card transactions. We treat the omnibus account as a protected client funds account: our Finance department reconciles the total of all individual cardholder balances against the bank account balance every single day to ensure they match to the cent. The account is clearly designated in our records as a “Customer Card Funds” account for card users. This means that at all times the funds are fully traceable to clients and, similar to e-money safeguards, if UTRG UAB were ever to fail financially, the funds in the omnibus account would be recognised as client-owned funds rather than company assets. We can also promptly return any remaining card funds to you upon request or if you terminate your card, after standard verification checks, since we maintain precise records linking each portion of the pooled fund to each client.
Organisational Oversight and Staff Training: Ensuring proper segregation is a company-wide responsibility at UTRG UAB. Compliance with our segregation procedures is mandatory for all employees and integrated into our daily operational controls. We limit access to client asset systems to only authorised personnel, and those individuals undergo background checks and specialised training in handling client assets. We have multi-level internal oversight: for instance, any movement of assets typically requires dual approval (the “four-eyes” principle) and goes through checks by our Compliance and Finance teams. Furthermore, our Internal Audit function conducts periodic audits of the segregation controls – examining everything from wallet setups to recordkeeping – to ensure that the rules are being followed and are effective. Senior management and the Board of UTRG UAB receive reports on these audits and any incidents. By implementing all of the above measures, UTRG UAB fully complies with the Bank of Lithuania’s requirements and MiCA regulations regarding the segregation of client assets. We give our clients confidence that their crypto-assets and funds are always protected, kept separate from the Company’s own accounts, and available to them at any time.