If an Iranian Exchange Goes Bankrupt, Is the User the Owner of the Assets or a Creditor?

Imagine you have 0.5 BTC and 10,000 Tether in an Iranian exchange account. The exchange is operating normally, your balance is displayed in the panel, and withdrawals have been possible until yesterday. Suddenly, withdrawals are halted, and shortly after, the company enters bankruptcy proceedings.

The crucial and legal question you need to answer is:

Is that 0.5 Bitcoin and 10,000 Tether still legally your asset that must be separated from the exchange's property and returned to you, or has the exchange become the owner of the asset and you only have a claim against the company?

These two situations lead to completely different outcomes.

If the asset still belongs to the user and can be identified as property belonging to another party in the bankruptcy process, the issue of <> may arise. However, if the legal relationship is such that the user merely has the right to claim a specific amount of cryptocurrency or its equivalent from the exchange, the user enters the realm of creditors.

An examination of current regulations in Iran shows that there is still no clear and uniform answer for all exchanges and all types of user balances.

This ambiguity is, in itself, the most significant finding of this report.

Summary of the answer: Under current regulations in Iran, there is no explicit ruling stating that all cryptocurrencies held at an exchange are necessarily excluded from the company's assets in the event of bankruptcy. The outcome may depend on the nature of the contract between the user and the exchange, how the assets are held, the ability to identify and separate the customer's assets, the exchange's authority to use the assets, and ultimately the interpretation of the court and the liquidator.

This article is a general analysis of regulations and does not replace legal advice regarding a specific case.

What do the new Central Bank regulations say about the bankruptcy of cryptocurrency exchanges? {#%D9%85%D9%82%D8%B1%D8%A7%D8%AA_%D8%AC%D8%AF%DB%8C%D8%AF_%D8%A8%D8%A7%D9%86%DA%A9_%D9%85%D8%B1%DA%A9%D8%B2%DB%8C_%D8%AF%D8%B1%D8%A8%D8%A7%D8%B1%D9%87_%D9%88%D8%B1%D8%B4%DA%A9%D8%B3%D8%AA%DA%AF%DB%8C_%D8%B5%D8%B1%D8%A7%D9%81%DB%8C%E2%80%8C%D9%87%D8%A7%DB%8C_%D8%B1%D9%85%D8%B2%D8%A7%D8%B1%D8%B2%DB%8C_%DA%86%D9%87_%D9%85%DB%8C%E2%80%8Cگ%D9%88%DB%8C%D8%AF%D8%9F}

On October 27, 2025, the Central Bank's High Council approved the <<Instruction for the Establishment, Operation, Dissolution, and Supervision of Cryptocurrency Brokers>>. This instruction contains 58 articles, and its eighth chapter is directly dedicated to <>. Article 50 mentions five conditions for a cryptocurrency broker to enter the dissolution process:

1. Revocation of the operating license by the Central Bank;
2. The Central Bank's refusal to extend the license;
3. Issuance of a definitive bankruptcy ruling;
4. Issuance of a dissolution ruling by the court;
5. Voluntary dissolution.

Article 52 also conditions voluntary dissolution on formal declaration, approval by the Central Bank, and following legal procedures.

However, the most important article for discussing user assets is Article 51:

<<In the event of bankruptcy or dissolution of the cryptocurrency broker, its liquidation shall be carried out in accordance with the relevant laws and regulations.>>

The full text of the instruction can be found in the regulations database, and another version of it is available on Iran Codify.

The problem lies precisely here. Article 51 does not specify the legal status of the cryptocurrencies registered in customers' accounts at the time of liquidation. There is no explicit ruling regarding these matters in Articles 50 to 52.

• Should customer assets be separated from the assets of the exchange?
• Does the customer's cryptocurrency become part of the divisible assets among creditors?
• Is the customer the owner of the cryptocurrency or merely a claimant?
• If users' assets are held in multiple pooled wallets, how is each user's share identified?
• Does the exchange have the right to use, collateralize, lend, or invest customer assets?
• Are customer assets protected from other creditors of the company?
• If the exchange's reserves are less than the total balance of users, how is the shortfall distributed among users?

Thus, merely having a chapter titled <> does not resolve the issue of user asset ownership.

Commercial Law recognizes a different path from <>: the return of property

To find part of the answer, we must step outside the specialized cryptocurrency regulations and refer to commercial law. Chapter ten of the bankruptcy section of commercial law is dedicated to <>.

Article 529 discusses properties that have been entrusted to a bankrupt trader and predicts their return as long as they are still in existence. Article 531 is even more explicit:

<<... In general, any property belonging to another that is in the possession of the bankrupt trader is recoverable.>>

The text of these articles is published in the commercial law database.

This ruling is of great importance for the issue of cryptocurrency exchanges, as it conceptually creates two completely different situations.

Situation One: This Bitcoin Belongs to the User

If it can be proven that the cryptocurrency held at the exchange still belongs to the user, ownership has not transferred to the exchange, and the asset is identifiable, the legal argument can move towards the recovery of property.

In this situation, the user says:

This 0.5 Bitcoin belongs to me and should not be considered part of the company's assets for paying its debts.

Situation Two: The Exchange Owes the User 0.5 Bitcoin

If the contract or operational structure indicates that ownership of the asset has transferred to the exchange or that the exchange was allowed to consume, lend, collateralize, or use it in its activities, the situation changes.

In such a structure, what is displayed on the user's dashboard as <<0.5 BTC>> may economically and legally resemble more a commitment by the exchange to deliver 0.5 Bitcoin than direct ownership by the user of a specific Bitcoin located at a certain address.

In that case, the issue becomes closer to a claim against the company.

And it is precisely this difference that becomes significant in bankruptcy.

Can cryptocurrency held at an exchange be considered <>?

Here, one of the most difficult legal issues of the case arises. In a personal wallet, the situation is relatively clearer. The private key is in the user's possession, and the transactions of the balance can be viewed on the blockchain.

However, centralized exchanges typically do not set aside a collection of physical coins or even an independent UTXO for each user. The common structure might look like this:

User 1: 0.5 BTC
User 2: 1 BTC
User 3: 0.2 BTC

But the exchange may keep the total of these assets in one or more omnibus wallets and record each user's share in its internal ledger.

In such cases, <<0.5 Bitcoin of user number 1>> is not necessarily a collection of specific satoshis in a dedicated address.

This complicates the determination of what exactly <> is.

Articles 528 to 531 of the Commercial Code were written at a time when Bitcoin, omnibus wallets, internal ledgers of exchanges, and interchangeable digital assets did not exist. Therefore, the direct application of these articles to cryptocurrency assets requires legal interpretation; existing regulations have not made this adaptation in advance.

The mere custody of the assets does not solve the issue
The Civil Code considers a deposit in Article 607 as a contract in which a person entrusts their property to another for safekeeping.

Article 612 also obligates the custodian to preserve the property, and Article 624 addresses the obligation to return the property to the rightful owner. The text of these regulations can be examined in the Civil Code.

However, one cannot simply equate the use of terms like <>, <>, or <> in marketing content by an exchange with proof of the existence of a deposit contract and the user's ownership of the property. The court will likely need to examine the entire relationship:

• The text of the Terms of Service;
• The registration agreement;
• Wallet regulations;
• Regulations on profit-generating or credit services;
• The accounting method for assets;
• The structure of the exchange's wallets;
• The possibility or impossibility of the exchange using the assets;
• How user debts are recorded in the company's books;
• And the actual behavior of the parties.

The name of the contract alone is not determinative; the nature of the relationship is more important.

The Terms of Service of the exchange may be more important than its advertisements

A user may encounter the following phrases on the homepage of an exchange:

Your assets
Your dedicated wallet
Assets are safe with us
Secure storage of user assets

However, for bankruptcy issues, one must go beyond the homepage and refer to the contract text. Five questions in the Terms of Service are particularly important.

1. Which legal entity is the contract party?

Users must know with which legal entity they are contracting. The brand name is not necessarily the same as the name of the company that may potentially owe the user. In bankruptcy cases, the registered name of the company, national ID, type of legal personality, and the contracting company become important.

2. To whom does the asset belong?

Phrases like these are important:

• The asset remains the user's;
• The exchange is merely a custodian;
• The account balance is the exchange's obligation to the user;
• Ownership of the asset is transferred upon deposit.

The difference in these phrases may not be noticeable to the user under normal circumstances, but it can be fundamental in bankruptcy.

3. Does the exchange have permission to use the assets?

This clause is one of the most important in the contract. Can the exchange:

• Lend the assets?
• Use them as collateral?
• Utilize them for market-making?
• Employ them in Earn services?
• Deposit them with another company?
• Mix them with its own assets?

If the answer is yes, the legal risk of the custodial relationship changes.

4. Are customer assets kept separate from company assets?

The key phrase in international financial standards is "segregation of client assets." Segregation does not merely mean having multiple cold wallets. The exchange may keep a large portion of cryptocurrencies in a cold wallet but still hold all users' assets and even part of the company's assets in a pooled structure.

The important issue is whether, legally, in accounting, and operationally, the customer's assets are separate from the company's assets.

5. What does the contract say about bankruptcy?

A precise contract should specify what happens to customer assets in the event of bankruptcy, dissolution, cessation of activities, or revocation of licenses. The absence of such a clause does not necessarily eliminate the user's ownership; however, it indicates that the legal relationship has not been clarified in the most critical failure scenario.

An example of ambiguity seen in the general regulations of Iranian exchanges {#%D9%86%D9%85%D9%88%D9%86%D9%87%E2%80%8C%D8%A7%DB%8C_%D8%A7%D8%B2_%D8%A7%D8%A8%D9%87%D8%A7%D9%85%DB%8C_%DA%A9%D9%87_%D8%AF%D8%B1_%D9%85%D9%82%D8%B1%D8%B1%D8%A7%D8%AA_%D8%B9%D9%85%D9%88%D9%85%DB%8C_%D8%B5%D8%B1%D8%A7%D9%81%DB%8C%E2%80%8C%D9%87%D8%A7%DB%8C_%D8%A7%DB%8C%D8%B1%D8%A7%D9%86%DB%8C_%D8%AF%DB%8C%D8%AF%D9%87_%D9%85%DB%8C%E2%80%8C%D8%B4%D9%88%D8%AF}

For example, in the general terms of use of the exchange, several notable phrases exist regarding the removal of an asset, stating that users' assets in the wallet are "held in trust." In another section, it discusses "the monetary amount... in the user's account wallet."

In the same contract, there are provisions for limiting withdrawals, correcting balances due to errors, deducting losses from the user's account, and restricting certain services. The full text can be seen in the terms and conditions of the exchange.

This example shows why reviewing a single sentence of the contract is insufficient.

To determine the status of assets in bankruptcy, the entire contract and operational structure must be considered together.

In another example, Valex had previously stated in an announcement regarding the potential closure of exchanges that users' cryptocurrency assets are kept in cold wallets and declared that "users' digital currency assets are solely in their control."

Such statements can be important for examining the expectations that the platform has created for the customer; however, from a bankruptcy perspective, the public claim of a company is not the same as creating a bankruptcy-remote legal structure or legally segregating customer assets.

This distinction should not be lost in the evaluation of exchanges.

Cold wallets do not solve the bankruptcy issue
One of the most common responses from exchanges to questions about the security of user assets is the use of a Cold Wallet. This response is important regarding cybersecurity, but it is not sufficient concerning bankruptcy rights.

A cold wallet can reduce the likelihood of online theft. However, it does not answer these questions:

• Who is the legal owner of the wallet's assets?
• How much does the exchange owe to users?
• Are the wallet's assets collateralized?
• Does a third party have rights to it?
• Does the customers' balance match the reserves?
• Are customer assets mixed with the company's assets?
• Can it be separated from the company's assets in bankruptcy?

Therefore:

Cold storage is a security control, not a legal answer to bankruptcy.

Proof of Reserves does not prove user ownership either
Proof of reserves also addresses a different issue. In a proper proof of reserves mechanism, the goal is to show that an exchange holds a specific amount of assets, and users' balances are also accounted for in the calculations.

Mehan Blockchain previously examined the PoR mechanism and its limitations in the article <<What is Proof of Reserves in Centralized Exchanges?>>. Another report titled <<Why Proof of Reserves Alone Does Not Build Real Trust? The Main Problem is Debts>> also addressed this issue.

PoR can help answer the question <<Is there an asset?>>. However, it does not necessarily answer:

Legally, who owns this asset?

An exchange may indeed have 10,000 Bitcoins in its wallets, but ownership, debts, collateral, third-party rights, and the position of customers in bankruptcy still require separate examination.

For this reason, proof of reserves is not proof of ownership.

Mehan Blockchain has previously examined the status of PoR in Iran in the article <<Is the Proof of Reserves System Necessary in Iranian Exchanges?>>.

The framework of the International Organization of Securities Commissions (IOSCO) precisely addresses points that still require greater transparency in current regulations in Iran.

In its final report, "Policy Recommendations for Crypto and Digital Asset Markets," published in November 2023, IOSCO presented independent recommendations for crypto platforms regarding the custody and protection of customer assets. The official page of the IOSCO report lists report FR11/23 among its official documents. IOSCO's orientation is based on several principles:

• Custody conditions must be clear to the customer;
• Customer assets must be properly identified and protected;
• The reuse of customer assets should not be ambiguous;
• Internal records should allow for the identification of each customer's rights;
• Risks related to third-party custodians must be managed;
• Regulators should pay attention to how client assets are protected, including in the event of intermediary failure.

IOSCO also published an independent report in 2014 titled "Recommendations Regarding the Protection of Client Assets." This report emphasized the correct registration of customer assets, appropriate segregation, and the protection of customer rights against the bankruptcy of financial intermediaries.

The main point of these standards is simple:

The security of customer assets is not just a hacking issue. It must be clear in advance where customer assets legally stand in the event of a company's failure.

Bank for International Settlements (BIS): A term in a contract that can convert the user from an asset owner to a creditor

The April 2026 report from the Financial Stability Institute, affiliated with the Bank for International Settlements (BIS), is one of the most relevant sources for this discussion.

This report titled Cryptoasset service providers as financial intermediaries: risks and policy approaches examines the conditions and regulations of a group of major crypto service providers between November 2025 and March 2026.

A key finding of the report is that some products known as Earn or investment are designed in such a way that they transfer the ownership of the customer's asset to the provider.

In this case, the company can use the asset for lending, market making, or other activities, and in return, the customer holds a right to repayment. From an economic perspective, the BIS describes this relationship as akin to creating a short-term debt for the company.

This distinction is not trivial. A user who thinks "my 10,000 Tether is in the exchange" may, based on the contract, actually be in a position where "the exchange is obligated to repay me 10,000 Tether."

These two statements may seem almost identical in the user interface. They are not the same in bankruptcy court.

When an exchange simultaneously engages in custody, lending, and market making, the risk increases {#%D9%88%D9%82%D8%AA%DB%8C_%D8%B5%D8%B1%D8%A7%D9%81%DB%8C_%D9%87%D9%85%D8%B2%D9%85%D8%A7%D9%86_%DA%A9%D8%A7%D8%B3%D8%AA%D8%AF%DB%8C%D8%8C_%D9%84%D9%86%D8%AF%DB%8C%D9%86%DA%AF_%D9%88_%D8%A8%D8%A7%D8%B2%D8%A7%D8%B1%D8%B3%D8%A7%D8%B2%DB%8C_%D8%A7%D9%86%D8%AC%D8%A7%D9%85_%D9%85%DB%8C%E2%80%8C%D8%AF%D9%87%D8%8C_%D8%B1%DB%8C%D8%B3%DA%A9_%D8%A8%DB%8C%D8%B4%D8%AA%D8%B1_%D9%85%DB%8C%E2%80%8C%D8%B4%D9%88%D8%AF}

The Bank for International Settlements (BIS) also warns about exchanges that combine multiple financial roles within one company. A platform may simultaneously:

• Serve as a trading venue;
• Hold customer assets;
• Provide loans;
• Offer trading credit;
• Engage in market making;
• Utilize customer assets in yield-generating programs;
• Offer derivatives.

The Bank for International Settlements (BIS) refers to these companies as Multifunction Cryptoasset Intermediaries or MCI. The combination of these activities can create liquidity, credit, maturity, leverage, and conflict of interest risks. The issue for the user is that they may think they are merely using a "exchange wallet", while their asset may be part of a complex financial intermediation chain.

For this reason, the terms and conditions for using spot services, wallets, credit, loans, and Earn should not be assumed to be the same.

The experience of FTX showed that the term "creditor" is not just a legal term {#%D8%AA%D8%AC%D8%B1%D8%A8%D9%87_FTX_%D9%86%D8%B4%D8%A7%D9%86_%D8%AF%D8%A7%D8%AF_%DA%A9%D9%84%D9%85%D9%87_%C2%AB%D8%B7%D9%84%D8%A8%DA%A9%D8%A7%D8%B1%C2%BB_%D9%81%D9%82%D8%B7_%D8%A7%D8%B5%D8%B7%D9%84%D8%A7%D8%AD%DB%8C_%D8%AD%D9%82%D9%88%D9%82%DB%8C_%D9%86%DB%8C%D8%B3%D8%AA}

After the collapse of FTX, customers of this exchange entered a lengthy bankruptcy process, and their claims were examined through judicial proceedings.

Mehan Blockchain reported that 98% of creditors of FTX will receive 118% of their assets in cash regarding one of the FTX repayment plans. Even the title "creditors" in this case indicates how a user's relationship with the exchange can transform from a simple balance on a screen to a claim in a legal case after a platform enters bankruptcy.

Cash repayment of a claim is not the same as returning the same crypto asset.

If a user has one Bitcoin in an exchange and their claim is calculated based on the dollar value of Bitcoin on a specific date, they may not benefit from any subsequent price increases of Bitcoin even after receiving the full amount identified in the case.

Therefore, the question "Am I an owner or a creditor?" is not just about the possibility of reclaiming money. The type of right the user has is also important.

Why has the Excoino case made this discussion more relevant for Iran?
Mehan Blockchain has covered Excoino's withdrawal issues in several stages since 2025. Initially, in the report "Review of Delays in Rial and Cryptocurrency Withdrawals at Excoino Exchange," user complaints about unusual delays were examined.

Subsequently, Excoino's official statement regarding withdrawal delays was published.

In Esfand 2025, Mehan Blockchain also investigated the status of this entity and its inability to settle some user claims in the special report "How did Excoino go from an alleged disruption to a systemic crisis?" The Excoino case raises a structural question:

When withdrawals are halted, what right does the number seen in the user's account actually create for them?

This question cannot be answered solely by the balance shown on the dashboard.

"Exchanges are not wallets" was a security warning; now we must also consider its legal layer
Mehan Blockchain previously wrote in the article "Exchanges are not wallets! Why you shouldn't keep your assets in an exchange account?" about the risks of long-term asset storage in centralized exchanges. In an older article, "The Concept of Exchange or Centralized Exchange Explained Simply," it was also recommended that long-term assets be kept in personal wallets.

The usual reason for this recommendation is hacking and control of the private key. However, the bankruptcy of the exchange adds another layer to it:

When the exchange controls the private key, the issue is not just who can sign the transaction; it is important who the law and contract recognize as the owner of the asset controlled by that key.

What can strengthen the user's legal position?

In the absence of a clear and specific ruling regarding bankruptcy remoteness of customer assets in current regulations, several factors may be significant in analyzing a case.

|-----------------------------------------------|--------------------------------------------------------| | Factor | Why is it important? | | Explicit contract stating ownership remains with the user | Strengthens the ownership argument | | Definition of the exchange as an agent or custodian | Can clarify the nature of the relationship | | Prohibition on the exchange's use of assets | Reduces the likelihood of converting the custody relationship into a financial debt | | Segregation of customer assets from company assets | Makes asset identification in liquidation easier | | Accurate records of each customer's share | Important for proving each user's entitlement | | Verifiable wallets and reporting liabilities | Increases the ability to match assets and obligations | | Independent auditing | Enhances the quality of evidence | | Specific insolvency clause | Clarifies the rights of the parties before a crisis | | Right to withdraw without unnecessary contractual limitations | Increases the user's economic control over the assets |

None of these factors alone guarantees that a court will consider the assets outside of the bankrupt estate. The overall legal, accounting, and operational structure is more determinative.

What should we look for in the contract of every Iranian exchange?
A user who wants to assess the real risk of an exchange should seek clear answers to the following questions instead of the vague phrase "User assets are safe":

• Asset Ownership: Does the contract explicitly state that ownership of the cryptocurrency remains with the user?
• Custody: Is the role of the exchange to hold the assets or to create a payment obligation?
• Segregation of Customer Assets: Are customer assets separate from the company's own assets?
• Commingling: Are user assets mixed with each other or with the exchange's assets?
• Rehypothecation: Does the exchange have the right to re-pledge or reuse the assets?
• Lending: Is there a possibility of lending customer assets?
• Market Making: Can customer capital be used to provide market liquidity?
• Third-party Custody: Are the assets held by another custodian?
• Insolvency: What rights are provided for the user in the event of the company's bankruptcy?
• Liability Limitation: Under what conditions has the exchange limited its liability?
• Withdrawal Conditions: What powers does the exchange have to stop withdrawals?
• Legal Entity: Which company is the legal party to the contract?

An exchange can be very strong in cybersecurity and still have a weak contract regarding customer ownership rights.

Three Different Models That Should Not Be Confused
To analyze the asset custody structure more precisely, it can be divided into three conceptual models.

Model One: Customer Segregated Assets

The assets remain the property of the customer, and the exchange only holds them. Records and legal structures allow for the identification of the customer's rights. This model is most similar to actual custody.

Model Two: Aggregated Assets with Customer Share Registration

The assets of multiple customers are held in shared wallets, but the exchange maintains an accurate ledger of each customer's share, and the contract recognizes customer ownership. Many operational structures of exchanges are closer to this model.
The main challenge during bankruptcy is identifying user shares and dealing with any reserve shortfalls.

Model Three: Transfer of Ownership and Creation of Debt

The assets are transferred to the company, and the company commits to return an equivalent later. This model can be seen in Earn, Lending, or similar products.
In such a situation, the user is more exposed to the credit risk of the company itself. The BIS has specifically warned about this imperceptible transfer from custody to financial intermediation.

Final Question: If an Iranian exchange goes bankrupt tomorrow, whose property is the user's Bitcoin?
With current regulations, a definitive answer cannot be given for all exchanges.
The Central Bank's cryptocurrency broker guidelines recognize the occurrence of bankruptcy and the dissolution process, but Chapter Eight does not specify the exact position of the customer's cryptocurrency in liquidation. Article 51 refers the matter of liquidation to relevant laws and regulations.
On the other hand, commercial law provides for the return of "the specific property belonging to another" from a bankrupt trader under certain conditions. Therefore, two scenarios can be imagined:

If the user can prove that the asset still belongs to them, that ownership has not been transferred to the exchange, that the asset is present and identifiable, and that the legal relationship was truly custody or trust, it can be argued that the matter goes beyond a simple claim and the possibility of return should be examined.
However:
If the asset cannot be separated, the exchange has the right to use it according to the contract, ownership has been transferred, or the relationship has effectively turned into a commitment by the exchange to repay a specific amount of cryptocurrency, the user's position may be closer to a claim against the company.
In situations between these two, the outcome will depend on the interpretation of the contract, the custody structure, accounting documents, the ability to trace the asset, and the opinion of the judicial authority.

Until Iran's regulations explicitly clarify the separation of customer assets, their true ownership, the possibility of reusing customer assets, and how to handle these assets in the event of bankruptcy, this legal risk remains. The number <<1 BTC>> on the exchange panel alone does not prove that a specific Bitcoin is outside the company's assets and belongs to that user. This issue should be clarified before bankruptcy; after bankruptcy, the matter is no longer just about technology and blockchain. It involves ownership, contracts, and creditors' rights.

Frequently Asked Questions (FAQ)

If an exchange selects another company as the custodian of users' cryptocurrencies, who is responsible? {#faq-question-1786858226046}

It depends on the contract. Using a third-party custodian can create a new layer of risk, and it must be clear how the legal relationship between the user, the exchange, and the custodian is defined.

If I have a dedicated deposit address, does that mean that wallet is legally mine? {#faq-question-1786858244284}

No. The exclusivity of the deposit address does not necessarily mean the user has legal ownership of the private key or the balance of that address. The exchange can control the key and later transfer the assets to pooled wallets.

If the exchange has 100% proof of reserves, is there no risk of bankruptcy? {#faq-question-1786858260424}

No. Proof of Reserves (PoR) does not provide a complete picture of the exchange's financial status without sufficient information about debts, collateral, third-party rights, and ownership structure.

Do the balances in Rials and cryptocurrencies have the same legal status? {#faq-question-1786858285279}

No. The nature of the assets, how Rials are held in the banking network, the exchange's contract, and the accounting structure can differ and must be examined separately.

Does having a license from the central bank guarantee the repayment of users' assets? {#faq-question-1786858299884}

No. A regulatory license is not the same as deposit insurance or government guarantees for the repayment of users' assets. The current guidelines do not provide such general guarantees for the assets of cryptocurrency exchanges.

If an exchange uses the term <> in the contract, is that sufficient? {#faq-question-1786858310443}

No. This term can be significant, but the reviewing authority may examine the entire nature of the relationship, how the assets are used, financial records, and the actual performance of the exchange.