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
Accept client money	No
Provide custody of customer assets	No
Issue external bank / crypto payment instructions to customers	Disabled on customer APIs
Credit accounts from external settlement	Not available as a customer self-service path
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:

1. Legal authorization / perimeter clearance for the entity and product.
2. Written bank, custodian, or wallet arrangements naming the correct Ohana Capital entity.
3. Segregation or safeguarding method required by local law (or an approved alternative).
4. Daily reconciliation between platform ledger, provider balances, and outstanding settlements.
5. Dual control on payouts and on changes to settlement destinations.
6. 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.

See Insurance, Retention, and Escalation Schedule.

8. Related documents

• Terms of Service
• Compliance Policy
• Execution and Liquidity Framework
• Entity and Licensing Scope