Zap (Strike) Europe Limited
(Version 1 | 1 June 2026)
Zap (Strike) Europe Limited (“Strike”), a Malta company with registered number C114533 and LEI 984500457TAB0A3BZ224, operating under the “Strike” brand, is authorised and regulated by the Malta Financial Services Authority (“MFSA”) as a crypto-asset service provider (“CASP”) under Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”) and the Markets in Crypto-Assets Act (Ch.647) of Malta.
Where you are a customer of Strike, Strike is responsible for the custody and administration of your bitcoin (crypto-assets) and your fiat money (funds) from the time that they are received until they are transferred away from Strike for instance when you withdraw them, or until they are used for instance as part of a purchase or sale or to pay transaction fees.
As an authorised CASP, Strike adheres to specific obligations set out under MiCA in relation to the safeguarding of client assets, both crypto-assets (bitcoin) and fiat funds, including having a detailed Custody Policy setting out how it manages, secures, and protects client assets, and how it complies with MiCA requirements relating to custody and safeguarding of client assets.
This document is a summary of our custody policy, intended to provide you information in relation to how we hold client assets. This document is not marketing material, but rather it’s intended to give you information to help you understand how your assets are held by Strike if you hold bitcoin in your Strike account.
Segregation
Strike applies market standard asset segregation practices to ensure that client crypto-assets are securely held and operationally separated from our own assets.
In practice this means that we hold your bitcoin separate from our own bitcoin, so that we can clearly identify “client assets” i.e. bitcoin we are holding for our customers, and “own assets” i.e. our own bitcoin which we hold for treasury or liquidity purposes.
This segregation is fundamental to protecting client assets and maintaining transparency in our custodial operations.
Safekeeping
We hold client bitcoin in secure infrastructure which has been designed and engineered for security, reliability, and in line with industry best practice. Client crypto-assets are stored in a combination of hot and cold wallets, with a strong emphasis on using cold wallets for long-term storage due to their enhanced security.
Any customer funds are safeguarded in a European bank (credit institution), and transferred to this account within at least one business day, in accordance with MiCA safeguarding requirements for fiat funds. We also work with other payments providers to process fiat deposits and withdrawals, including individual customer IBANs or account information.
Like many custodians, we hold customer assets on an “omnibus” basis. This means that whilst we track each customer’s individual cash and bitcoin balance so we have detailed records of the assets we are holding for any individual customer, the assets themselves are held on an aggregated and omnibus basis.
This means that each client’s crypto-assets are managed within our omnibus custody wallet infrastructure, including different wallet types for secure storage, including nodes, multi-signature wallets, and cold wallets. Individual client balances tracked individually through Strike’s internal ledger system.
Assets will cease to be client assets and safekeeping assets from the moment that they are either transferred out based on a client’s instruction (for instance a withdraw or transfer), or sold. For example fiat funds will cease to be client assets if they are withdrawn or used to purchase bitcoin, and bitcoin will cease to be client assets if it is withdrawn or sold for fiat funds. In addition, where funds or bitcoin is due to Strike, for instance as a transaction fee or network fee, they will cease to be client assets (and deducted from your balance) when that fee is due, deducted or paid.
Ownership
You retain full beneficial ownership of your crypto-assets that we hold in custody for you, at all times. Strike acts solely as custodian and does not acquire any beneficial interest in the assets it safeguards on your behalf.
We treat your assets that we hold in custody for you as fiduciary assets which means that, under Maltese law, they are legally segregated and benefit from statutory protections including in the event of our insolvency.
No rehypothecation
Strike does not use clients’ crypto-assets that it holds in custody as safekeeping assets for its own purposes, or otherwise rehypothecate customer crypto-assets.
Security
In addition to operational segregation, Strike employs advanced security measures, including multi-signature wallets, offline key storage, whitelisting, encryption, and regular reconciliations, to safeguard assets.
These measures are complemented by a robust operational framework that includes strict access controls, security protocols, logging, key management, and continuous monitoring of custodial activities, alongside our Information Security program designed to keep our systems secure.
Clients can choose to apply additional security measures on their own device and account, including biometrics (such as FaceID), and two-factor authentication (2FA) to further protect their account access including on their device.
As custodian, Strike owns and controls the cryptographic private keys associated with the wallets used to hold client crypto-assets (“private keys” or “keys”). Strike has robust security protocols relating to the generation, storage, use and preservation of private keys, in line with market standards for leading bitcoin custodians.
Record keeping
The Custody Policy ensures that each client’s rights to their bitcoin held with Strike is recognised and protected. Each client’s rights to their assets are reflected in a detailed register of positions maintained by Strike in its internal ledgering systems. These systems record the specific holdings of each client, tracking all movements, including deposits, withdrawals, and transfers, and are continuously updated on an automated basis to ensure we have accurate records of client’s holdings at any given time. In short: our systems allow us to ensure that we know who we hold bitcoin for, and how much bitcoin we hold for them.
The register of positions is a vital tool that supports the legal and operational framework of the custody services. It ensures that any movement affecting a client’s assets is promptly recorded and that each client’s ownership is clearly defined and respected. The internal systems are designed to handle these updates efficiently and seamlessly, ensuring that any client instructions (such as a buy, sell, or transfer) are accurately recorded, and a client’s custody asset balance updated. All transactions are subject to ongoing monitoring and review to ensure compliance with regulatory requirements and internal policies such as anti money laundering and fraud.
Custody Agreement
The custody agreement is contained with Strike’s Terms of Service (User Agreement) agreed to by all its clients. This sets out the custody terms, and other terms applicable to the custody services provided by Strike, and the basis on which those services are provided.
Compliance and Risk Management
Strike operates within a robust compliance framework that aligns with the latest regulatory standards, including the MiCA. Compliance is central to all custody operations, ensuring that client assets are managed in accordance with both legal requirements and best industry practices. Our risk management procedures are designed to identify, assess, and mitigate risks associated with the custody and administration of crypto-assets. Strike has a dedicated compliance team that monitors regulatory developments and ensures that all necessary adjustments to policies and procedures are made promptly.
Reporting
Clients have full visibility into their bitcoin balance through their Strike App, either via the mobile application or the web portal, where they can view monthly statements of their positions, transaction history, and any relevant updates.
Client Communication and Support
Strike always intends to communicate clearly, and effectively, with its clients. Clients can contact Strike’s customer support team with any questions relating to their custody services including by email, or within the Strike App.
The customer support team is trained to handle a wide range of inquiries, from basic account management to more complex questions about custody operations and asset movements.
Strike’s Terms of Service (User Agreement) is freely available on its website.
This summary of the custody policy in an electronic format is shared with users if requested. It may be updated from time to time, so please check with us if you have any questions.