Anchorage Digital Singapore Disclosures

Last updated: October 2024

Anchorage Digital Singapore Pte Ltd (ADS) has been granted full approval from the Monetary Authority of Singapore (MAS) to provide digital payment token (DPT) services and other payment services. ADS is based in Singapore and provides its services from Singapore. MAS requires us to provide the below risk warning to you as a client. Before you pay your DPT service provider any money or DPT, you should be aware of the following: 

1. Risk Warning on Digital Payment Token Services: MAS requires us to provide this risk warning to you as a client of a DPT service provider. 

Before you:

• pay or transfer ADS any money or DPT; 
• enter into an agreement with a third party to buy or sell DPTs  under an arrangement by ADS; 
• enter into an agreement with a third party under an arrangement by ADS for the transmission of DPTs; 
• pay a third party any money or DPT under an arrangement by ADS for the transmission of DPTs; or 
• transfer any digital payment token instrument to ADS; 

You should be aware of the following:

• ADS has obtained full approval from the MAS to provide DPT and other payment services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to ADS or any other third party referred to above, if ADS or the third party’s business fails. 

• You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by ADS. 

• You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens. 

• You should be aware that ADS, as part of its license to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.

2. Your use of ADS products and services, including custody and trading services, are subject to certain terms and conditions. The legal terms and conditions that apply to you as a client of ADS are as described in the master service agreement(s) executed between you and ADS. The master service agreement(s) provides the arrangements for receiving instructions from you and providing information to you, and applicable fees and costs, among other terms and conditions.

3. At all times, all of your assets held with ADS are safeguarded by ADS. All ADS client accounts are held on behalf of each client and segregated from the assets of ADS, and in most scenarios, from the assets of other clients, in dedicated on-chain vaults.  Each wallet address is independent and segregated. The existence of each client’s wallet address can be verified on the respective public blockchain. In addition to wallet address segregation, each client's private keys are securely managed and encrypted ensuring that each client has exclusive access to their assets.

4. In certain situations, your DPTs may be commingled with the DPTs of other ADS clients. This occurs in omnibus staging accounts owned by ADS to facilitate trading services. Similarly, your fiat currency may be held in an account for the benefit of (FBO) ADS clients at a licensed Singapore bank insured by the Singapore Deposit Insurance Corporation. In both scenarios, when commingling occurs, your individual interest in the assets may not be identifiable by separate physical documents. However, ADS maintains detailed records to precisely track your ownership within these accounts. This ensures that your DPTs and fiat assets remain allocated to you, and your ownership and control are not affected. 

5. In the event of the failure of ADS' business or a significant cybersecurity incident, there is a risk that you may not be able to recover all of the DPTs held in your ADS account(s).  A  business failure refers to situations where ADS is unable to continue its operations for reasons  such as insolvency, cessation of business, loss of critical assets (including due to a cyber security incident), or regulatory action.  ADS has taken measures to mitigate these risks.  Key elements include:

• Account Acceptance & Authorized Person Designations.  ADS only provides services after a potential client completes our account acceptance process.  Once a client’s account is accepted, the client designates Authorized Persons to use the account.  A client can add or remove Authorized Persons in accordance with our processes.  Authorized Persons can initiate the deposit or withdrawal of DPTs and the withdrawal of fiat through the web dashboard, the iOS app, and via API. ADS holds your assets on trust and, subject to certain rights of lien and setoff and fees for on-chain services described below, a client is solely entitled to the assets held on trust and to any ancillary rights, including income or staking rewards, arising from such assets. 
• Segregating Client Assets. ADS holds client assets on trust for the client’s benefit and such assets are not part of ADS’ balance sheet, consistent with the safeguarding requirements outlined in MAS’ Payment Services Act Amendment Regulations 2024 and Guidelines on Consumer Protection Measures by DPT Service Provider.  These measures help protect client assets from becoming part of the ADS’ liquidation pool in an insolvency scenario. Clients receive periodic statements reflecting their DPTs in custody and can view their assets at any time through the web dashboard, the iOS app, and via API.
• Insurance. ADS maintains insurance coverage for a range of risks, including crime (theft, robbery, burglary, third-party computer and funds transfer fraud), cyber/tech errors & omissions (professional liability), and general liability (third-party injury/damage). Clients may submit a claim to their client representative through the company-approved communication channel. ADS’ will then undertake a specialized review depending on whether the claim resulted from a technological incident or concerns of fraud or theft. Upon completion, ADS will inform a client of the investigation's outcome. 
• Digital Asset Storage Security Measures. ADS securely stores your digital assets and implements robust security measures, but the risk of loss due to events such as cybersecurity incidents cannot be entirely eliminated. ADS employs reasonable security measures to protect your DPTs. We employ industry-leading security measures to safeguard your assets. Your assets are held in offline cold storage 100% of the time, significantly reducing the risk of unauthorized access. Private keys, crucial for accessing your assets, are generated and stored securely offline using cutting-edge technology. Additionally, we utilize biometric authentication, quorum approvals by client’s authorized users, and dual-check verification to ensure only authorized personnel can access and transact with your assets.
• Anchorage's Responsibility and Loss Handling. In the event that you lose your DPTs due to fraud, willful misconduct, or gross negligence on the part of ADS, the company will be held responsible for your losses. This means that ADS will take steps to compensate you for the value of your lost DPTs. The specific process for seeking compensation and any limitations on ADS’ liability are outlined in  the terms and conditions that accompany the master service agreement. In the unlikely event of a loss, please contact ADS’ client support team promptly to initiate the claims process.

6. All of your DPTs are held on trust for your benefit and are not part of ADS’ balance sheet. In the event of ADS’ insolvency, client assets do not become part of the liquidation pool and cannot be subject to ADS’ creditor claims. Access and control over your assets would be transferred according to the instructions of the receiver or liquidator appointed by the bankruptcy court for return to the client.

7. ADS  does not provide legal, tax, or investment advice. Holdings of DPTs are speculative and involve a substantial degree of risk, including the risk of complete loss. There can be no assurance that any DPTs will be viable, liquid, or solvent. No ADS’ communication is intended to imply that any DPT services are low-risk or risk-free.

8. Digital Payment Token Assessment Framework

ADS provides a trading solution to enable traders to access and make trades in supported digital assets that have passed our Assessment Framework. Before enabling a digital asset for support for trading, we will conduct a risk assessment that covers various dimensions, including AML/TF risks, custody risks, technology risks, reputational risks, market integrity, fraud and legal risks.

Key elements of our framework, as illustrated above are:

• Rigorous Risk Assessment: We conduct in-depth evaluations of each digital asset, including its purpose, market capitalization, technical design, and governance model for all the above listed risk categories.
• Multi-Team Collaboration: Business Development, Engineering, Compliance, and Legal teams collaborate to assess and document risks across various domains.
• Regulatory Adherence: Our framework ensures strict compliance with MAS guidelines, particularly Notice PS-N02.
• Executive Oversight: New token listings and associated services require approvals from ADS Executive Management Team.
• Continuous Improvement: The framework is regularly reviewed to keep pace with evolving regulatory developments.

These enhancements reinforce our commitment to providing a safe and compliant platform for digital asset trading and custody services in Singapore.

We monitor and assess on a continuous basis the digital assets we support. If we decide to discontinue support for a digital asset, this may affect your ability to submit new orders to trade the digital asset, and/or your ability to keep holding the digital asset through ADS. We will generally aim to  notify via email to any current clients holding said asset and remove the asset from anchorage.com in advance to allow users to transfer these digital assets to other wallets or platforms. Any communications issued will include the reasons for delisting, the timeline, and instructions on how to withdraw the digital assets.

If you have any queries regarding our Assessment Framework and support for any digital assets, please email contact@anchorage.com.

Other Disclosures: 

Currently all exchange rates are denominated in US Dollars on Anchorage platforms, and SG Dollar exchange rate is not  available at the point of transaction.

The exchange rates applicable to your foreign currency transactions are based on the rates provided by our correspondent banks. These rates are subject to change and may vary from publicly available rates. 

Your DPTs are processed using hardware security modules (“HSMs”) located within your jurisdiction. However, for contingency purposes, we maintain backup HSMs in the United States owned by our ultimate parent company, Anchor Labs, Inc., so that you maintain uninterrupted  access to your DPTs in the event of a disruption.  ADS will retain custody of your DPTs in the event that a transaction is processed by an offshore HSM and your DPTs will not enter the custody of an affiliated entity or otherwise leave the jurisdiction of Singapore.  

Before you open your account, please review the full terms and conditions that accompany the master service agreement for comprehensive information on account acceptance, fees, and our lien and right of setoff against your DPTs in the event of nonpayment.  ADS charges fees in connection with its custody, brokerage, fiat, and on-chain services, including staking, voting, vesting, signaling, and other activities requiring interaction with the applicable blockchain. ADS may also charge a one-time onboarding fee at the outset of the client relationship. To ensure that you fulfill your payment obligations, the terms and conditions grant ADS a lien and legal right to setoff the DPTs in your account(s). After providing you with notice, ADS can use these assets to satisfy outstanding fees. 

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