Trakx (the “Company” or “Trakx”) is a crypto-asset service provider operating in accordance with the applicable laws and regulatory framework of the European Union and France.
Trakx has implemented organisational, technical and governance measures designed to safeguard Customersʼ crypto-assets, including segregation arrangements, custody controls and operational resilience mechanisms, in line with applicable regulatory requirements and industry standards.
While these measures aim to reduce the risks associated with the custody of crypto-assets, Customers acknowledge that crypto-asset services inherently involve operational, technological and market risks, and that no custody framework can eliminate such risks entirely.
In accordance with Article 75(3) of Regulation (EU) 2023/1114 on Markets in Crypto-assets (“MiCA”), this summary of Trakx’s custody policy (the “Policy”) is published in electronic format on Trakx’s website (www.trakx.io) and is accessible to Customers and prospective Customers at all times. It describes the key principles and safeguards applied for the protection of Customers’ crypto-assets..
This Policy applies to all aspects of crypto-asset custody carried out by Trakx on behalf of its Customers, to the extent and for the duration that Trakx is authorised under Regulation (EU) 2023/1114 (MiCA) to provide crypto-asset custody services.
It covers, in particular, the safeguarding of crypto-assets, segregation arrangements, access and authorisation controls, transaction verification, regulatory compliance, and incident and recovery management.
Before providing custody services, Trakx and the Customer enter into a written custody agreement (signing the T&Cs), executed electronically, specifying the terms, rights, and obligations applicable to the custody of crypto-assets.
Trakx relies on a dedicated MPC-based custody infrastructure provided by a third-party technology and security infrastructure provider. This provider supplies cryptographic key-management and wallet technology supporting secure custody operations; however, it does not assume custodial responsibility vis-à-vis Clients.
Custodial responsibility for Clientsʼ crypto-assets remains at all times with Trakx. The MPC-based infrastructure is used to operate segregated custody wallets and vaults with clearly defined operational purposes, enabling traceability, access control and segregation of Clientsʼ crypto-assets in accordance with MiCA requirements.
Trakx maintains a real-time register of crypto-asset positions and transactions for each Customer, ensuring continuous traceability, reconciliation, and auditability of all movements.
Custody wallets are operated using multi-party computation (MPC) technology, enabling secure management of crypto-assets through multi-validation processes and role-based access controls.
Where Trakx relies on third-party service providers for the performance of certain custody-related functions, Trakx remains responsible towards Customers to the extent required under Regulation (EU) 2023/1114 (MiCA), subject to applicable law and the contractual allocation of responsibilities.
Trakx distinguishes at all times between:
Trakx has put in place organisational, technical and accounting controls intended to ensure the segregation of Customersʼ crypto-assets from Trakxʼs own assets and to mitigate the risk of commingling, in line with applicable regulatory requirements.
The custody infrastructure and internal ledger systems support segregation by design, enabling clear identification of ownership, auditability, and reconciliation.
In addition, Trakx has implemented organisational, technical and governance arrangements aimed at achieving the operational and legal segregation of crypto-assets held in custody from the Companyʼs own estate, including in insolvency or wind-down scenarios, subject to applicable insolvency law and court determinations.
Trakx has implemented robust security measures for the safeguarding of crypto-assets, including controlled access to custody wallets, role-based permissions, multi-step transaction approval, and continuous monitoring.
Trakx controls, on behalf of its Customers, the means of access to crypto-assets through documented governance, operational controls and multi-party computation (MPC) mechanisms. Access credentials and cryptographic material are generated, stored and operated using industry-standard MPC-based custody infrastructure, ensuring that no single individual or entity holds unilateral control over private keys, and in accordance with applicable regulatory and security requirements.
Trakx facilitates the exercise of Customersʼ rights attached to crypto-assets, including the execution of transfers upon Customer request.
The Company also ensures that its custody technology provider applies appropriate security standards with respect to wallet generation, key management, storage, backup, and recovery procedures.
Trakx has implemented mechanisms to facilitate the exercise of rights attached to crypto-assets and to ensure that any event likely to create or modify a Customerʼs rights (an “Event”) is promptly identified and recorded.
Such Events include, but are not limited to, protocol upgrades, forks, airdrops, and other events affecting crypto-asset rights.
Upon detection of an Event, Trakx assesses its implications for Customersʼ assets and rights and informs affected Customers in a clear and timely manner of the nature and impact of the Event.
Where changes to distributed ledger technology or other Events (such as protocol upgrades, forks or similar occurrences) give rise to new rights or crypto-assets, Customers are entitled to such rights or crypto-assets in proportion to their holdings at the time of the Event. Any limitation, exclusion or alternative treatment of such rights shall be clearly disclosed to Customers in advance, set out in applicable contractual documentation, and implemented in a manner consistent with MiCA requirements and applicable consumer protection rules.
Trakx regularly tests its disaster recovery and business continuity arrangements to ensure continuity of access to Customer crypto-assets.
Upon a valid Customer request, Trakx processes the return of crypto-assets within standard operational timeframes, subject to the completion of required verification checks.
As a general rule, withdrawal requests are processed within one (1) business day following successful verification of the Customerʼs identity, entitlement and compliance status. Execution may take longer where additional checks are required, including but not limited to enhanced AML/CFT controls, network congestion, blockchain maintenance, or circumstances beyond Trakxʼs reasonable control.
Transfers are executed using secure and encrypted custody infrastructure and controlled workflows designed to ensure accuracy, traceability and security. Customers are informed without undue delay of any material factor likely to affect processing timelines.
Customers are kept informed of the status of their request throughout the restitution process, and dedicated support channels are available to address questions or concerns.
Where restitution becomes temporarily or permanently impossible due to events not attributable to Trakx, the Company informs affected Customers without undue delay, explains the circumstances, and makes commercially reasonable efforts to provide alternative solutions.
Incidents that are not attributable to Trakx include events arising independently of Trakxʼs custody activities, such as disruptions or failures inherent to the operation, integrity or evolution of the relevant distributed ledger technology.
The attribution of any incident is assessed on a case-by-case basis, in accordance with Regulation (EU) 2023/1114 (MiCA), applicable contractual arrangements, and relevant national law, taking into account Trakxʼs duties of care, control and oversight.
Where an incident affecting the custody of crypto-assets meets applicable regulatory notification thresholds, Trakx notifies the competent authorities, including the Autorité des marchés financiers (AMF), without undue delay and in accordance with applicable legal and regulatory requirements.
Trakx provides Customers, via its “Assets” page on its website, with a statement of position in electronic format, identifying:
Customers are also informed promptly of any operations requiring their attention or action.
Trakx is liable to its Customers for the loss of crypto-assets or the means of access thereto resulting from incidents attributable to Trakx, notwithstanding the involvement of any third-party service provider.
Any limitation of liability applicable to Trakx in respect of the loss of crypto-assets is subject to mandatory provisions of applicable law and regulatory requirements. As a general principle, and without prejudice to such mandatory protections, liability is assessed by reference to the market value of the crypto-assets at the time the loss occurred. This summary does not constitute an exhaustive description of Customersʼ rights or Trakxʼs obligation
