1. Status of this document

This Client Money and Custody Framework is a counsel working draft. It states the current no-client-money posture and the target controls that must exist before Ohana Capital accepts or safeguards real customer funds or assets.

It is not evidence that client money is currently accepted or that a custody license is held.

2. Current state (binding until changed)

Topic	Current state
Accept client money	No
Provide custody of customer assets	No
Issue external bank / crypto payment instructions to customers	Disabled on customer APIs
Credit accounts from external settlement	Not available as a customer self-service path
Balances shown in the product	Platform ledger / workflow records; not proof of segregated client assets

Customer deposit and withdrawal request endpoints return an external-settlement-disabled response while the product boundary flag remains off. CRM operator tools used for walkthrough scenarios do not change the public boundary description in this framework.

3. Definitions for a future live model

For counsel drafting of live terms:

• Client money — cash belonging to a customer and held for that customer under applicable client-money rules.
• Custody — safekeeping or controlling customer securities, crypto-assets, or other instruments.
• Omnibus / segregated — account structures at banks, custodians, or wallets used to hold customer assets.
• Settlement — movement of cash or assets to or from an external beneficiary.

4. Target principles before accepting real funds

No live acceptance of client money or custody should begin until counsel confirms that the following are in place for the relevant jurisdiction:

1. Legal authorization / perimeter clearance for the entity and product.
2. Written bank, custodian, or wallet arrangements naming the correct Ohana Capital entity.
3. Segregation or safeguarding method required by local law (or an approved alternative).
4. Daily reconciliation between platform ledger, provider balances, and outstanding settlements.
5. Clear customer disclosures on protection, insolvency treatment, and whether deposit insurance applies (if any).
6. Freeze / recall / investigation workflows for suspicious or mismatched transfers.
7. Independent audit or assurance obligations where required.

5. Proposed live funding lifecycle (target)

Customer request → eligibility & KYC gates → instruction issuance
→ external transfer → provider confirmation → ledger credit
→ ongoing reconciliation → withdrawal request → dual control → payout

Each step must leave an immutable audit trail (actor, timestamp, amount, reference, status).

6. Prohibited practices (current and live)

• Instructing customers to send funds to personal or unapproved third-party accounts
• Commingling client money with operating funds contrary to applicable rules
• Representing simulated balances as safeguarded client assets
• Claiming deposit-guarantee or investor-compensation coverage that has not been confirmed in writing

7. Insurance and protection

No customer deposit insurance, investor compensation scheme, or custody insurance is asserted in this framework. If such coverage is obtained for a live launch, the policy name, insurer, scope, limits, and exclusions must be added here and in customer disclosures before marketing.

See Insurance, Retention, and Escalation Schedule.

8. Related documents

• Entity and Licensing Scope Framework
• AML and KYC Procedures
• Execution and Liquidity Framework
• Terms of Service
• Risk Disclosure