Bitkaya BCMS — Compliance Management System

This wiki contains the authoritative Business Continuity Management System for Bitkaya B.V., a Curaçao-licensed Virtual Asset Service Provider regulated by the Centrale Bank van Curaçao en Sint Maarten (CBCS).

Structure

Sources

Regulatory sources — laws, ordinances, guidelines, and international standards that establish Bitkaya's compliance obligations.

Requirements

Derived requirements — specific obligations extracted from regulatory sources, mapped to policies and controls.

Policies

Compliance manuals — 21 policy documents covering AML/CFT/CPF, KYC/CDD, risk management, IT/cybersecurity, governance, and more.

Procedures

Step-by-step procedures implementing each policy requirement.

Controls

Controls that verify and enforce compliance with procedures.

Systems

Systems and tools used for compliance operations — Crystal Intelligence (blockchain analytics), Odoo (ERP/compliance), and others.

Processes

High-level business and compliance process flows.

Governance

Architecture decisions, specifications, and governance framework.

Glossary

Defined terms used across the BCMS.

Publications

Generated compliance manuals as PDFs — available for download.

About

For questions about this BCMS, contact Bitkaya B.V. compliance.