Last updated: December 2025.

1. Introduction

Aplo SAS (“Aplo”) is currently registered as a Digital Asset Service Provider (DASP) with the French Autorité des Marchés Financiers (AMF). Aplo is currently in a transitional phase, upgrading its operational and legal framework to fully comply with the EU Regulation 2023/1114 (MiCA). This statement outlines our high standards of security, segregation, and asset protection during and after this transition.

2. Legal Ownership and Bankruptcy Remoteness

• Proprietary Rights: You remain the sole legal and beneficial owner of the crypto-assets in your Aplo account. Aplo does not claim any title to your assets, and they are never recorded on Aplo’s balance sheet.
• Insolvency Protection: Pursuant to Article 70 of MiCA, client assets are held in a manner that makes them “bankruptcy-remote.” In the event of Aplo’s insolvency, these assets are strictly isolated from Aplo’s estate and protected from the claims of Aplo’s general creditors.
• No Re-hypothecation: Aplo is strictly prohibited from using, lending, or pledging your assets for its own account or for any other purpose without your prior, express, and specific instruction.

3. Technical Safeguarding: HSM, TEE & MPC

Aplo secures private keys using institutional-grade technology through industry-leader wallet technology partners:

• Hardware Security Modules (HSM) & Trusted Execution Environments (TEE): Private keys are generated and stored and processed within HSMs and TEEs. Keys are never accessible in plaintext.
• MPC Architecture: We utilize Multi-Party Computation (MPC) to distribute key shards across multiple secure environments, requiring a quorum of shards to authorize any movement of assets.

4. Segregation Models: Omnibus vs. Dedicated Wallets

• Omnibus Model (Standard): By default, Aplo utilizes pooled (omnibus) wallets. While commingled on-chain, Aplo maintains a strict off-chain sub-ledger identifying each client’s entitlement in real-time.
• Dedicated Wallets (Optional): Clients may opt for dedicated on-chain wallets for their custody account, providing a higher level of on-chain transparency and segregation.
• Sub-custodians: To facilitate trading operations, Aplo may utilize regulated EU-based sub-custodians. These partners undergo rigorous due diligence to ensure their security standards align with MiCA requirements.

5. Fiat, EMT, and Conversion Services

• No Fiat Custody: Aplo provides crypto-to-fiat exchange services with fiat settlement but does not provide fiat custody services. Fiat funds are processed directly via authorized third-party payment service providers.
• E-Money Tokens (EMT): Aplo supports the custody of E-Money Tokens (EMT). We provide seamless 1:1 conversion between fiat and EMT to facilitate immediate trading while maintaining a crypto-native environment for our clients.

6. Continuous Reconciliation

Aplo performs daily reconciliations between its internal sub-ledger and the balances held across our omnibus wallets, dedicated wallets, and sub-custodian accounts, ensuring 1:1 backing of all client entitlements at all times.

7. Reversibility, Wind-Down, and Business Continuity

Aplo maintains a comprehensive Wind-Down and Business Continuity Plan, designed to ensure that client assets remain protected and accessible even in the event of a significant operational disruption or a formal cessation of services.

• Orderly Wind-Down: In the event that Aplo decides to cease its custody services or loses its regulatory status, we have established protocols to manage an orderly wind-down. This includes providing clients with a formal notice period and clear instructions on how to migrate their assets to an external wallet or another regulated provider.
• Operational Continuity: Our infrastructure is built with redundancy to prevent service interruptions. In the event of a technical failure, our Business Continuity Plan (BCP) ensures that critical custody functions (including asset recovery and reconciliation) can continue using backup systems and secure data restores.
• Data Portability: As part of our reversibility commitment, Aplo ensures that all necessary records, transaction histories, and ownership proofs are maintained in a portable format. This facilitates the seamless transition of your account data and asset entitlements to a successor entity or a third-party custodian if required.
• Asset Recovery: Our Disaster Recovery (DR) protocols, based on our HSM/MPC architecture, allow for the secure restoration of access to crypto-assets even in extreme scenarios where our primary interfaces are unavailable.