An asset-management proposal should explain who makes investment decisions, under what mandate and with control over which assets. The mandate and operational permissions must align.[1]
Understanding the question
Map customer authority, discretion, custody, valuation, reporting and risk limits. Identify the entity providing the service and any delegated functions. A dashboard showing customer balances does not explain who is legally and operationally responsible for decisions.[1]
Build the working record
| Consideration | What to establish |
|---|---|
| Mandate | What decisions is the provider authorised to make? |
| Assets | Where are assets held and who can move them? |
| Reporting | How are decisions, performance and risks communicated? |
Put it into practice
If a client can withdraw funds but cannot approve each investment, describe the manager’s discretion clearly in the operating model.
Ape Law and this subject
Ape Law publishes a service for VARA licence applications. Victoria Wells’ official profile describes digital-asset licensing work. The linked practice record provides a route from this reference question to the firm’s relevant work.[3][4]
Ape Law’s VARA application supportReferences
Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.
- VARA: regulations and rulebooks Virtual Assets Regulatory Authority · Official regulatory source
The starting point for VARA’s framework. Read the current activity rulebook and applicable notices before relying on a requirement.
- Ape Law: VARA licence applications Ape Law · Service description
Describes application support. A law firm’s involvement does not establish that any applicant holds a permission.
- Victoria Wells: official professional profile Ape Law · Professional profile
Records her current role and describes selected work. First-party experience statements remain attributed to this profile.
Compiled 25 September 2026. Source availability and legal requirements can change. Read the citation method.