Mauritius VAITOS: Custody + Marketplace Pilot
Separated roles (custody vs marketplace), client asset segregation, and incident playbooks tested with the regulator under a VAITOS-style stack. An anonymized planning-stage pilot.
Snapshot
$0 (sandbox) Investors
0 (testing only) Timeline
4 months (pilot) Stage
Planning / Regulator testing Platform
Local Licensee Status
Playbooks validated; go/no-go pending Anonymized
Context & Objectives
Objective: Prove an operating model where custody (client assets) is operationally segregated from the marketplace (order matching/offerings), with clear responsibilities, audit trails, and incident handling aligned to local expectations.
- Map roles/responsibilities: custody, marketplace, issuer on-ramps, payments.
- Demonstrate client asset segregation (omnibus vs fully-segregated), reconciliations, and proof-of-control.
- Run tabletop incident tests with the regulator: lock/pause, comms, remediation.
VAITOS Stack & Role Separation
Licensed custodian holds client assets with segregation, daily reconciliations, withdrawal policies, and dual-control approvals.
Separate licensed marketplace for primary/secondary; performs KYC checks, venue allowlists, and disclosure distribution.
Local fund interest issuance; registrar maintains unit-holder records and corporate actions.
Key Terms & Controls (Pilot)
| Instruments | Fund Interests (testing flows only) |
| Client asset model | Segregated sub-accounts; reconciliation SOD/EOD |
| KYC/AML | Tiered IDV, PEP/sanctions; geography blocks |
| Ops playbooks | Pause/lock, incident comms, asset recovery steps |
| Disclosures | Risk, fee schedule, custody terms, escalation paths |
Provider Stack
Local licensed custodian (segregated accounts, reconciliations)
Local licensee for offerings/secondary with registry
Fund unit register, corp. actions, investor statements
IDV provider, sanctions/PEP screening, SoF/SoW tiers
Local bank rails; reconciliation engine; payout workflows
Local counsel drafting T&Cs, custody agreements, disclosures
Operations & Regulator Test Cases
- Onboarding: eligibility + KYC; investor classification stored in registry.
- Subscription: e-docs; funds received → units allocated; confirmations issued.
- Reconciliation: T+0 client asset checks; variance thresholds trigger review.
- Incidents: scripted tabletop: wallet compromise, AML alert, system outage.
- Reporting: admin statements, fee breakdown, exception logs to regulator.
Timeline (Pilot Plan)
| Phase | Workstreams | ETA |
|---|---|---|
| Design | Role maps, segregation model, disclosure pack | 2–3 weeks |
| Setup | Custody accounts, marketplace configs, KYC flows | 3–4 weeks |
| Dry run | Tabletop incidents, reconciliation tests, reports | 2 weeks |
| Regulator review | Demo + documents; remediation if required | Ongoing |
Key Risks & Mitigations (Pilot)
RACI matrix; public docs clarify responsibilities.
Daily reconciliations; variance alerts; audit trails.
Tiered reviews; escalation to MLRO; periodic refresh.
Pause/lock controls; incident comms; regulator notification SOP.
Downloads
This case is anonymized; downloads are generalized templates.
Piloting a VAITOS-style stack?
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