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Aave

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Bonk

Algorand

Lido DAO

GALA

The Sandbox

Ethereum Name Service

ApeCoin

Decentraland

Compound

Curve DAO

yearn.finance

SushiSwap

Your information is handled in accordance with CoinJar’s [Privacy Policy](https://www.coinjar.com/ie/privacy). 

**Warning: If you invest in this product, you may lose some, or all, of the money you invest. The value of crypto-assets may rise or fall rapidly. Past performance is not indicative of future results. To learn more see our [Risk Disclosures](https://www.coinjar.com/ie/risk-disclosure).**

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Cryptocurrency Prices

CoinJar offers some of the most competitive prices on Bitcoin, Ethereum and other established cryptocurrencies.

For more information on this data and our pricing, please read our [Commercial and Pricing Disclosure](https://www.coinjar.com/ie/commercial-pricing-mechanism-disclosure).

### Learn more about CoinJar’s trading fees

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Customer assets are held in custody by CoinJar Europe Limited using Fireblocks' secure wallet infrastructure as a technology provider.

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Custody & Safeguarding

### 1. Purpose

CoinJar Europe Limited ("**CoinJar Europe**", "**CEL**", "**the Firm**", "**we**", "**our**" or "**the Company**") is a wholly-owned subsidiary of CoinJar Group Holdings Pty Ltd and is authorised by the Central Bank of Ireland (“**CBI**”) as a Crypto-Asset Service Provider (“**CASP**”). 

Safeguarding the crypto-assets and fiat held on a temporary basis for our customers is at the heart of everything we do. It underpins market integrity, protects our brand and meets the legitimate expectations of regulators, auditors and most importantly of our customers.

This Custody & Administration Disclosure articulates how we maintain continuous, verifiable control over customer crypto-assets and fiat, from the moment they enter our custody through to their safe return or are used for an exchange service. It explains our governance model, technology, operational processes and assurance activities in clear, measurable terms so that stakeholders can judge the adequacy of our control environment.

Collectively, these documents demonstrate our commitment to the highest standards of customer-asset protection across the entire asset-lifecycle, even in the face of market stress or Firm wind-down.

**Regulatory Permissions**
| ARTICLE 3 (1)(16) DEFINITIONS | Use Case |
|:-:|:-:|
| Providing custody and administration of crypto assets on behalf of clients | CoinJar Europe is responsible for the safekeeping or controlling, on behalf of its customers, of crypto-assets or of the means of access to such crypto-assets, where applicable in the form of private cryptographic keys. |
| Exchange of crypto-assets for funds | CoinJar Europe receives fiat funds from its customers to purchase crypto assets. CoinJar Europe acts as the principal in conversion using its own crypto-asset inventory. |
| Exchange of crypto-assets for other crypto-assets | Enabling CoinJar Europe to buy crypto assets from their customers who wish to convert from one crypto asset to another type of crypto asset. CoinJar Europe acts as the principal in conversion using its crypto-asset inventory. |
| Providing transfer services for crypto assets on behalf of clients | CoinJar Europe receives a request from a customer to transfer the custodianship of a virtual asset to another entity or wallet. |

<br></br>

**Scope of the Custody and Administration Service**

This Disclosure applies to all custody and administration services provided by CoinJar Europe. These services include:
- Safekeeping of crypto assets on behalf of customers.
- Administration of crypto-assets, including facilitating customer access and exercising rights attached to the crypto-assets.
- Safekeeping of customer fiat funds on behalf of customers
- Ensuring the return of crypto assets and fiat funds or means of access to customers upon request or during insolvency scenarios.

The scope covers (combined known as “**relevant assets**”):
- Crypto assets under custody held directly by CoinJar Europe apply to all customer types.
- Fiat balances held by CoinJar Europe while awaiting instructions from customers

**Regulatory Framework**

This Disclosure is developed in accordance with Regulation (EU) 2023/1114, specifically Article 75, which governs the custody and administration of crypto assets. It aligns with the requirements outlined in Article 62 for crypto-asset service providers seeking authorisation. CoinJar Europe adheres to all relevant regulatory obligations, including:
- Ensuring compliance with Article 75(8) regarding safekeeping and control of customer crypto-assets.
- Providing customers with a summary of the custody Disclosure, as required by Article 75(3).

### 2. Definitions

| Term | Meaning |
|:-:|:-:|
| Customer Asset | A crypto-asset or the cryptographic means of access (e.g., private-key share, seed phrase, hardware signer) entrusted to the Firm for the benefit of the customer. |
| Custody | The holding of the means of access sufficient to unilaterally dispose of a crypto-asset. |
|Administration | Book-keeping, reconciliation, order action processing and other back-office functions that evidence the customer’s title to a crypto-asset. |
| MPC-CMP | Fireblocks’ Multi-Party Computation – Conditional Multi-Party protocol whereby multiple key shares are held in separate secure enclaves, so that the full private key never exists in a single place. All key shares are required for a transaction. |
| Vault Class | Classification of wallet clusters (Hot, Warm, Cold) based on their connectivity, signing-key location and transaction limits. |
| HCAO | Head of Customer Asset Oversight is the Controlling Function 45 under CBI Fitness & Probity. |
| RTO / RPO | Recovery Time Objective / Recovery Point Objective as defined in ISO 22301. |
| TPSP | Third-Party Service Provider—any external party contracted to provide ICT or operational services relevant to Customer Assets (presently this is “**Fireblocks**”). |

<br></br>

### 3. Risk Appetite Statement

CoinJar Europe recognises the critical importance of protecting relevant funds due to customers.  It has a zero-tolerance approach to risks that could compromise the protection, segregation, and proper management of relevant funds:
- **Zero-tolerance stance**: The Board will not accept any risk that could compromise the segregation, protection, or timely return of relevant funds.
- **Regulatory primacy**: MiCAR and Central Bank safeguarding rules take precedence over operational convenience or commercial gain.
- **Segregation & co-mingling prohibition**: Relevant funds must always be held in designated accounts/wallets; the assets of CoinJar Europe, or any other CoinJar entity, may never share those accounts/wallets.
- **Operational controls**: Only a very low tolerance exists for errors or system failures. Operation breaks must be escalated and remediated immediately, and related scenarios are captured in the risk register.
- **Third-party vetting**: Minimal tolerance for risks posed by technical partners, banks or payment partners. Rigorous due diligence and monitoring are mandatory.
- **Liquidity discipline**: Zero appetite for any activity that could create a shortfall or delay in meeting customer withdrawals.
Insolvency and wind-down preparedness: Frameworks and contingency plans must guarantee full protection of customer assets if the Firm becomes insolvent or decides to wind down.
- **Reputational vigilance**: Low tolerance for potential damage arising from regulatory findings or public scrutiny of safeguarding practices.

### 4. Core Principles

CoinJar Europe segregates relevant assets by means of a segregation method that is, by keeping customer fiat and crypto assets separate (non-commingled) from all other funds/assets held by CoinJar Europe. 

The following high-level principles apply to the segregation of customers’ relevant assets by CoinJar Europe:

**Fiat Funds Held**

1. CoinJar Europe uses a segregated/customer money bank account opened with authorised credit institutions to segregate and safeguard the customers’ funds entrusted. CoinJar acknowledges that it is not a bank or payment firm; therefore, controls are in place to ensure that funds held for customers are not indefinitely maintained in the customer money account (held at Clear.Bank Europe).

2. Funds received are deemed relevant funds once available and are segregated immediately through the use of virtual IBANs (“vIBANs”).

3. CoinJar Europe will make sure that assets held on the customer money account(s) are always matched at least one to one to the value of the customer's funds that must be segregated and will conduct reconciliation of the customers funds daily to ensure that the parity is achieved by the end of the operating day.

4. CoinJar Europe will keep an efficient and adequate process to ensure it can identify customer funds held at any moment. 

5. CoinJar Europe will ensure that proper due diligence is conducted when selecting a new customer money account provider, and that periodic monitoring of the provider is conducted by the Head of Risk.  

6. Customer money letters are kept on file, which clearly sets out that the funds held on behalf of the customer do not form part of CoinJar’s proprietary assets.

**Crypto Assets Held in Custody**

1. CoinJar Europe safeguards customers’ crypto-assets in dedicated on-chain wallets that are pooled. 

2. Once an inbound transaction receives the requisite network confirmations, the crypto assets are treated as “relevant assets” and are automatically swept into the customer’s unique deposit wallet address and onto a segregated pooled wallet (known internally as “**omnibus**”).

3. CoinJar Europe maintains a minimum 1:1 match between the on-chain balances in customer wallets and the entitlements recorded in its internal ledger. Full reconciliations are performed each business day so that any break is identified and rectified before the close of business.

4. Robust ledgering, wallet-tagging, and blockchain analytics tools enable CoinJar Europe to identify, at any moment, the precise quantity and location of each customer’s crypto-assets.

### 5. Custody Arrangements

**Custody Service Offered**

CoinJar Europe provides a crypto (digital) asset custody service using omnibus digital wallets. This structure has the following characteristics:

- Customer crypto assets are received into unique customer wallets to enable unambiguous identification and are recorded on-chain as such.
- Customer assets are then pooled into collective omnibus accounts. This enables operational efficiency while maintaining robust tracking mechanisms. Customers provide explicit consent to the use of omnibus accounts when agreeing to CoinJar Europe Terms & Conditions.
- Segregation of individual customer holdings is achieved at the ledger level, where detailed records ensure accurate identification and reconciliation of each customer’s assets. This is a live ledger that is automatically updated and regularly reconciled.
- All customer assets are strictly separated from CoinJar’s proprietary assets, in compliance with regulatory requirements. 

**Description of the Custody Process and Procedures**

The custody process follows a structured approach to ensure the safekeeping and administration of customer crypto assets:
1. **Asset Onboarding**:
    - Once an account is verified, dedicated wallet addresses are assigned to each customer for incoming transactions, enabling unambiguous identification of funds.
    - Upon receipt of customer crypto-assets, CoinJar performs verification and reconciliation on the blockchain to confirm ownership and integrity.
2. **Safekeeping**:
    - CoinJar Europe leverages Fireblocks MPC (Multi-Party Computation) technology to ensure the highest level of security for customer crypto-assets. Key features include:
        - Cryptographic splitting of private keys into multiple shares, ensuring the private key is never fully reconstructed.
        - Use of Intel SGX (Software Guard Extensions) hardware-isolated enclaves to securely store MPC key shares.
        - Distributed signing processes across tier-1 cloud environments, reducing single points of failure.
        - Key Management Processes including assigning an Owner of the Fireblocks Workstation responsible for approving Key Signers. In CEL’s case, the HCAO is the Owner of the Fireblocks EU Workstation. 
3. **Ledger-Based Segregation**:
    - Individual customer holdings are segregated and automatically tracked at the ledger level, ensuring transparency and accountability. These ledgers are reconciled frequently.
4. **Monitoring and Reporting**:
    - Continuous monitoring and reconciliation of custody accounts is conducted to identify and mitigate risks. CUstomers have real-time online access to our web and mobile applications with details of their holdings and transactions.
    - As CoinJar does not provide banking services, customers cannot hold fiat currency in their CoinJar account indefinitely. The HCAO is responsible for monitoring customer’s fiat ‘time spent’ in the ClearBank Fiat accounts. Any fiat not used to transact within 12 months, will be returned to the customer. 
5. **Asset Return**:
    - Processes are in place to ensure the timely return of crypto-assets or means of access upon customer request or during insolvency scenarios.

### 6. Systems and Controls

CoinJar Europe employs comprehensive systems and internal control arrangements to manage operational and ICT risks, ensuring the safekeeping and administration of customer crypto assets as well as the timely execution of customer orders: 
1. **Segregation of Customer Assets**:
    - All customer crypto assets are stored in secure wallets, leveraging Fireblocks MPC technology to ensure cryptographic security and operational resilience.
    - Customer holdings are segregated at the ledger level to ensure accurate tracking and reconciliation.
    - Dedicated wallet addresses are assigned for incoming transactions to enable unambiguous identification.
    - Fiat funds in holding are maintained in dedicated customer money accounts at ClearBank.
2. **Access Control Mechanisms**:
    - Strict Role-Based Access Control (“**RBAC**”) is enforced to limit access to custody systems and sensitive data.
    - Multi-Factor Authentication (“**MFA**”) is required for all administrators and users accessing the custody platform.
3. **Transaction Authorisation Policies**:
     - Comprehensive policies are in place to enforce transaction limits, approval workflows, and risk-based authorisation parameters. 
     - Admin quorum requirements ensure that sensitive actions require approval from multiple administrators. 
4. **Customer Rights and Asset Return**:
     - Procedures are established to ensure customers can exercise their rights attached to the crypto-assets.
     - Mechanisms are in place to facilitate the timely return of customer crypto-assets or means of access upon request or during insolvency scenarios.
5. **Monitor and Detect Risks**:
     - Real-time monitoring tools are used to identify operational disruptions, unauthorised access, and ICT vulnerabilities.
     - Incident response systems enable swift escalation and resolution of identified risks.
6. **Ensure Resilience**:
    - High-availability infrastructure is deployed to minimise downtime and ensure uninterrupted service delivery.
    - Backup and disaster recovery systems are regularly tested to ensure operational continuity.
7. **Protect Customer Assets**:
    - Systems are designed to safeguard customer crypto-assets from operational failures, cybersecurity threats, and external risks.
    - Stringent access control mechanisms are enforced to prevent unauthorised access to custody systems.

### 7. Exercising Customer Rights Attached to Crypto-Assets

CoinJar Europe has systems designed to ensure customer can exercise rights attached to their crypto assets effectively. However, CoinJar Europe acknowledges certain practical limitations regarding participation in blockchain governance activities, the terms of which are detailed in its terms and conditions.

1. **Limited Participation in Governance Protocols**:
    - CoinJar Europe does not facilitate customer participation in blockchain governance activities, such as voting, staking, or actively managing hard forks and token migrations.
    - This stance reflects practical considerations, including blockchain protocol risks, technological uncertainties, potential security vulnerabilities of new or emerging protocols, and possible technical constraints in supporting new networks at the same standard and rigour required by this Custody and Administration Disclosure.
    - Customer who wish to participate in governance decisions or specific blockchain events (e.g., token migrations, forks) that are not Business-as-usual have two choices:
        i. Withdraw their crypto assets to self-hosted wallets to maintain full autonomy over their assets.
        ii. Complete an exception form for the given event that will be reviewed and executed on a case by case basis by CoinJar Europe. The execution of certain events may require additional costs incurred to be on-charged to the customer.
2. **Exceptional Circumstances**:
    - CoinJar Europe reserves the right, at its discretion, to intervene proactively in certain major or mandatory blockchain events that materially impact customer assets. Examples of such scenarios include significant hard forks or compulsory token migrations involving widely supported digital assets.
    - In these exceptional cases, CoinJar Europe will clearly communicate the nature of the event, actions required, and any involvement it intends to undertake to support customers.
3. **Distribution of Financial Benefits**:
    - In cases where CoinJar Europe derives a direct financial benefit from blockchain governance events (e.g., token distributions resulting from forks or protocol upgrades), and where such distributions can be readily liquidated but not practically distributed to customers in-kind, CoinJar Europe will distribute the resulting financial proceeds proportionately to customers based on their recorded asset holdings at the time of the relevant event.
4. **Rights Notification**:
    - CoinJar Europe will promptly notify customers of relevant blockchain events, such as protocol upgrades or significant network changes. These notifications are provided for informational purposes only and do not constitute active management or facilitation by CoinJar Europe unless explicitly stated otherwise.
5. **Blockchain Integration**:
    - Direct integration with blockchain networks ensures accurate processing of customer requests related to validly accepted asset management functions.

### 8. Ensuring the Return of Crypto-Assets or Means of Access to Customers

CoinJar Europe has systems to ensure the timely return of crypto-assets or means of access to customers upon request or during insolvency scenarios:
1. **Asset Return Protocols**:
    - Procedures are in place to verify customer identity and authorise the return of crypto assets securely.
    - Dedicated wallet addresses are used to facilitate the return process, ensuring unambiguous identification of funds.
2. **Reconciliation and Reporting**:
    - Ledger-level segregation ensures accurate tracking of customer holdings, enabling seamless reconciliation during asset returns.
    - Reporting provides transparency to customers regarding their holdings and return status.
3. **Insolvency and Wind Down Planning**:
    - Wind Down Plan in place for execution if required.
    - Systems are designed to enable efficient distribution of customer assets in the event of insolvency, including:
        - Access to books and records detailing customer holdings
        - Reconciliation and rebalancing tools to ensure accurate asset distribution

### 9. Delegation and Outsourcing

CoinJar Europe does not delegate or outsource custody and administration services to third parties. All customer crypto assets remain under the direct custody and administration of CoinJar Europe, ensuring full control and accountability. Fireblocks is utilised solely as a technology provider, supplying infrastructure and tools to enhance the security and operational efficiency of custody systems.

### 10. Location of Books and Records

CoinJar Europe maintains comprehensive books and records related to customer assets and transactions. These records are stored securely and are accessible for audit and regulatory purposes.

### 11. Regular Reviews and Updates to the Disclosure

CoinJar Europe conducts reviews and updates to the custody and administration Disclosure to ensure its continued relevance and effectiveness. The Disclosure is reviewed at least annually or in response to significant changes in regulatory requirements, market conditions, or operational risks.

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Cryptocurrency	Index price
BitcoinBTC		View BTC
EthereumETH		View ETH
SolanaSOL		View SOL
USDCUSDC		View USDC
XRPXRP		View XRP
DogecoinDOGE		View DOGE
CardanoADA		View ADA
AvalancheAVAX		View AVAX
Shiba InuSHIB		View SHIB
ChainlinkLINK		View LINK
Trump MemeTRUMP		View TRUMP
PolkadotDOT		View DOT
UniswapUNI		View UNI
LitecoinLTC		View LTC
PepePEPE		View PEPE
StellarXLM		View XLM
SuiSUI		View SUI
AaveAAVE		View AAVE
dogwifhatWIF		View WIF
Fetch.aiFET		View FET
The GraphGRT		View GRT
BonkBONK		View BONK
AlgorandALGO		View ALGO
Lido DAOLDO		View LDO
GALAGALA		View GALA
The SandboxSAND		View SAND
Ethereum Name ServiceENS		View ENS
ApeCoinAPE		View APE
DecentralandMANA		View MANA
CompoundCOMP		View COMP
Curve DAOCRV		View CRV
yearn.financeYFI		View YFI
SushiSwapSUSHI		View SUSHI

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