Whether holding a client's private keys is a licensable activity is the question that decides how a digital asset business is built, and in the Gelephu Mindfulness City the answer is usually yes. Safeguarding virtual assets for others is a Regulated Activity in the Gelephu Mindfulness City Special Administrative Region (GMC), known as Providing Custody.

Determine whether your model is Providing Custody, Arranging Custody, or outside both under the custody exclusions.

Prepare the Financial Services Licence application to the Gelephu Financial Services Office (GFSO), including the Approved Person filings.

Draft key management, hot and cold wallet, segregation and reconciliation policies that meet the GEN Rulebook systems and controls.

Structure client asset arrangements against the Client Money and client asset rules GFSO may make and the COBS rulebook.

Design outsourcing and sub-custody arrangements that satisfy the GEN Rulebook on outsourcing and material outsourcing notifications.

Advise exchanges on whether in-house custody requires a separate permission alongside the exchange permission.

Specialist digital asset custodians and wallet-as-a-service providers. Exchanges and brokers holding client assets in-house. Fund administrators and trustees safeguarding Fund Property. Technology providers unsure whether key-management software crosses into custody.