Custody model and operational wallets

Objective

This page summarizes the custody model declared by Swapo and the security controls of the wallets it uses to execute the transactions requested by clients.

Swapo declares that it does not provide virtual asset custody services, under Law No. 14,478/2022 and the regulations of the Central Bank of Brazil. It therefore understands that its activity should be classified as non-custodial, in the authorization request as an SPSAV in the intermediary category.

Declared model: no custody

Swapo declares that it:

• does not provide virtual asset custody services;
• does not hold clients' virtual assets under its permanent safekeeping;
• does not exercise exclusive, discretionary or lasting control over clients' private keys;
• does not offer safekeeping, ongoing administration or conservation services for virtual assets.

When virtual assets pass through addresses controlled by Swapo, that passage is exclusively transitory, automatic and instrumental. Its sole purpose is to enable the technical execution of the purchases, sales or transfers requested by the client.

Transactional wallets

The wallets used by Swapo are merely transactional:

• they serve exclusively to settle transactions;
• they have no prolonged safekeeping functionality;
• they are not offered to the client as a storage or custody service;
• they do not allow Swapo to use the assets at its discretion.

The client may not keep assets under Swapo's safekeeping for an indefinite period or for the purpose of preserving wealth.

Regulatory framing

Law No. 14,478/2022 includes the custody and administration of third-party virtual assets among virtual asset services. Swapo's declaration records that, on the date it was issued, the law and regulations did not establish an objective time criterion for characterizing custody, especially when the assets merely pass through the provider's addresses to execute a transaction.

For this reason, Swapo distinguishes custody proper from the transitory and instrumental holding inherent in the technical execution of transactions. As an auxiliary interpretive criterion, it uses international references, such as the guidance of the Swiss supervisory authority (FINMA) and the approaches of the European Union and the United Kingdom, which consider the degree of control over the assets, the duration and purpose of the holding, and the possibility of discretionary use.

These references do not replace Brazilian regulation, which Swapo must observe in full.

Security layers of the operational wallets

To protect the wallets it uses to execute transactions, Swapo provides for a three-layer architecture, with logical and operational segregation between the layers. The layers are security controls for Swapo's own operational wallets and do not change the declared model: Swapo does not offer safekeeping of clients' assets.

• Hot wallets: connected to the internet for immediate settlement of transactions, with maximum balance limits, multi-factor authentication, restricted access, multiple internal validations for movements and continuous transaction monitoring.
• Warm wallets: an intermediate layer, with controlled and non-permanent connectivity, used to balance liquidity and reduce the exposure of hot wallets. Movements require approval from multiple responsible persons.
• Cold wallets: kept offline, with no direct remote access and with controlled physical access. They are moved only in previously authorized events, with multiple approvals and distinct responsible persons.
• Clients' virtual assets are not kept in these layers: they only pass through, automatically and for less than 24 hours, the settlement wallet on their way to the wallet indicated by the client.

The architecture also seeks to minimize the exposure of assets to internet-connected environments, strictly control access and permissions, segregate duties among the technical, operational and compliance areas, and record all movements.

Movement between layers

Movement between the layers follows formal, documented and previously approved procedures, which include:

• verification of the operational need;
• validation by distinct responsible persons, with segregation of duties;
• complete recording of the transactions;
• subsequent review by the compliance and internal controls areas.

Extraordinary movements are subject to enhanced controls.

Risk and third-party management

The wallet architecture is integrated with the policies on information security, operational and technological risk management, business continuity, and prevention of money laundering and terrorist financing. Periodic reviews of the architecture, security tests and vulnerability assessments are provided for, carried out directly or by specialized third parties.

When part of the technology infrastructure relies on service providers, Swapo must select suppliers with recognized technical capacity, maintain contracts that ensure security, confidentiality and continuity, continuously monitor the services, and retain its full responsibility toward clients and authorities.

Review

Swapo commits to reviewing the non-custody declaration if there is a relevant change in its operating model, if the Central Bank of Brazil issues specific regulation on custody criteria, or if the supervisory authority requires additional adjustment.

The wallet architecture must be reviewed whenever there is a relevant change to it, to the associated risks or to regulatory requirements, with notice to, or a request for prior authorization from, the Central Bank of Brazil, as the case may be.

Regulatory basis and references

• Law No. 14,478/2022.
• Central Bank of Brazil regulation applicable to SPSAVs.
• As an auxiliary interpretive reference: guidance from FINMA (Switzerland) and approaches of the European Union and the United Kingdom on the distinction between custody and transitory holding.

About this version

Public version of the document “Declaration of Non-Custody of Virtual Assets and Virtual Asset Custody Architecture”, dated September 21, 2026, which is part of the authorization request filed with the Central Bank of Brazil. Authorization has not been granted yet.

This text summarizes the internal document. Personal data (LGPD), monitoring parameters and technical details whose disclosure would undermine security, fraud prevention and anti-money laundering efforts have been omitted, as have terms subject to business confidentiality (BCB Resolution No. 520/2025, art. 52, § 2). This version does not replace the service agreement or the applicable regulations.

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