Client Money and Custody Framework
How client money and asset custody will be safeguarded, and the controls required before launch.
- Document type
- Information policy
- Category
- Client protection
- Version
- 2026-08-24
- Effective
- August 24, 2026
- Issued by
- Ohana Capital AG
Notice
On this page8 sections
1. Purpose
This Client Money and Custody Framework sets out how Ohana Capital AG handles client money and custody today, and the safeguarding standards that must be in place before client funds or assets are accepted. It supports the Terms of Service and the Compliance Policy.
2. Current state
| Topic | Current state |
|---|---|
| Provide custody of customer assets | No |
| Balances shown in the product | Platform ledger / workflow records; not proof of segregated client assets |
This state applies until the requirements in section 4 are met and the change is published with a new version of this framework and the related customer documents.
3. Key terms
- Client money — cash belonging to a customer and held for that customer under applicable client-money rules.
- Custody — safekeeping or controlling customer securities, crypto-assets, or other instruments.
- Omnibus / segregated — account structures at banks, custodians, or wallets used to hold customer assets.
- Settlement — movement of cash or assets to or from an external beneficiary.
4. Safeguarding standards before launch
Acceptance of client money or custody begins only after the following are confirmed for the relevant jurisdiction:
- Legal authorization / perimeter clearance for the entity and product.
- Written bank, custodian, or wallet arrangements naming the correct Ohana Capital entity.
- Segregation or safeguarding method required by local law (or an approved alternative).
- Daily reconciliation between platform ledger, provider balances, and outstanding settlements.
- Dual control on payouts and on changes to settlement destinations.
- Documented complaint, incident, and failure-handling procedures for client-asset events.
5. Operating rules once live
When client money is accepted, the framework requires:
- Client funds held separate from operational funds under the applicable client-money rules
- Reconciliation performed on a defined daily cycle with discrepancy escalation
- Payouts released only under dual authorization
- Settlement destinations verified against account ownership before release
- Records sufficient for external audit and regulatory review
6. Prohibited representations
Ohana Capital personnel and partners may not:
- Claim client-money protection, segregation, or custody arrangements that are not in place
- Present internal platform balances as safeguarded client assets
- Claim deposit-guarantee or investor-compensation coverage that has not been confirmed in writing
7. Insurance and protection
No customer deposit insurance, investor compensation scheme, or custody insurance is asserted in this framework. If such coverage is obtained for a live launch, the policy name, insurer, scope, limits, and exclusions are added here and in customer disclosures before any marketing reference.
Questions about this document?
Contact Ohana Capital AG and include the document title and version in your message.
