BCMS

Client Complaints Handling Manual

8 min read

Bitkaya is committed to protecting the interests of its clients and stakeholders by ensuring that all complaints are handled in a manner that is prompt, fair, transparent, and consistent. This manual establishes the Complaints Management Policy and related procedures, providing clear guidance on how complaints should be received, acknowledged, investigated, resolved, and monitored.

1. Purpose and Scope

The purpose of this manual is threefold:

  1. Regulatory Compliance – to align with the requirements of the CBCS Regulation on Complaints Handling (2017), as well as relevant international standards and best practices.
  2. Customer Protection – to ensure that clients and stakeholders feel confident that their concerns will be addressed respectfully and fairly.
  3. Organizational Improvement – to use complaints as a valuable source of feedback that helps identify risks, strengthen internal controls, and improve services.

The scope of this manual applies to all complaints received from clients, business partners, investors, or other stakeholders concerning:

  • Bitkaya’s products and services.
  • Staff conduct, professionalism, or behavior.
  • Regulatory compliance and contractual obligations.
  • Ethical standards or fairness in dealing.

Complaints may be submitted orally, in writing, or electronically. All complaints, regardless of form, must be logged and addressed in line with the procedures described herein.

2. Definitions

  • Complaint: Any expression of dissatisfaction, whether justified or not, about Bitkaya’s products, services, staff, or representatives. Examples include service delays, product malfunctions, regulatory or contractual concerns, staff misconduct, or allegations of unfair treatment. The use of the word “complaint” by the client is not required for an issue to be treated as a complaint.
  • Complainant: Any natural or legal person, including clients, partners, investors, or stakeholders, submitting a complaint through the designated channels. The complainant has the right to acknowledgment, a fair investigation, and timely resolution.

3. Complaints Management Policy

  • Endorsement: The policy is formally approved and endorsed by Bitkaya’s Senior Management.
  • Documentation: The policy is documented, regularly updated, and accessible to all staff members.
  • Integration: It forms part of Bitkaya’s internal control framework and risk management system.
  • Review: Management will review the effectiveness of the policy at least twice per year, ensuring alignment with CBCS requirements and evolving best practices.

4. Complaints Management Function

  • A designated Complaints Officer is responsible for overseeing all complaints-handling activities.
  • Responsibilities include acknowledgment, investigation, resolution, escalation, reporting, and recordkeeping.
  • Independence is safeguarded: complaints officers cannot investigate complaints related to their own work or decisions.
  • Officers must possess adequate knowledge of Bitkaya’s services, regulatory environment, and demonstrate impartiality, professionalism, and strong communication skills.

5. Complaint Submission Channels

Complaints can be submitted via the following channels:

To enable efficient handling, complainants should provide:

  • Full name and contact details.
  • Clear description of the complaint.
  • Relevant dates, documentation, or evidence.

Bitkaya ensures that submission channels remain accessible, user-friendly, and secure.

6. Acknowledgment of Complaints

  • Bitkaya will confirm receipt in writing within 5 business days.
  • Within 2 weeks, the complainant will receive:
    • Confirmation of complaint registration.
    • Contact details of the assigned Complaints Officer.
    • Indicative timeframe for investigation and resolution.
  • Complainants will also be informed of their rights, including escalation options if dissatisfied.

7. Complaints Register and Recordkeeping

  • Complaints are recorded in a centralized, secure electronic register.
  • The register includes:
    • Complainant details.
    • Date of receipt.
    • Description and potential impact.
    • Status (open, under investigation, resolved).
    • Resolution details and final response date.
  • All complaints data is retained for at least 10 years after resolution.

8. Investigation Process

The Complaints Officer will:

  • Conduct an impartial and thorough investigation.
  • Collect and review all relevant evidence, documentation, and witness statements.
  • Engage relevant internal teams (Compliance, Finance, IT) or external experts where necessary.
  • Ensure confidentiality at all times, protecting personal data and sensitive information.
  • Document all steps taken to create a clear audit trail.

9. Resolution and Response

  • Resolution Timeline: Bitkaya aims to resolve complaints within 30 business days from acknowledgment.
  • Delays: If additional time is required, the complainant will be informed of the reason and provided with a revised timeline.
  • Final Response: Delivered in writing and will include:
    • A clear summary of the complaint.
    • Key findings from the investigation.
    • The decision and rationale.
    • Any remedial or corrective actions (refunds, adjustments, staff retraining, etc.).
  • All responses are written in clear and understandable language and stored in the complaints register.

10. Internal Follow-Up and Reporting

  • Complaints data is regularly analyzed to identify root causes, trends, and systemic issues.
  • Senior management will review findings at least every 6 months, with minutes recorded.
  • Reports will include complaint volumes, categories, resolution timelines, and root-cause analysis.
  • Bitkaya will provide complaints data to the CBCS upon request, ensuring full regulatory transparency.

11. Provision of Information

Bitkaya will:

  • Provide written information on the complaints procedure upon acknowledgment or request.
  • Publish the procedure clearly and accessibly via:
    • Brochures and client pamphlets.
    • Client contracts.
    • Bitkaya’s website.
  • Ensure all published information is accurate, up-to-date, and easy to understand.

12. Escalation Process

If a complainant is dissatisfied with Bitkaya’s final response, they may escalate the matter to external bodies, including:

  • The Central Bank of Curaçao and Sint Maarten (CBCS).
  • The Ombudsman.
  • The Court of Justice.
  • An Alternative Dispute Resolution (ADR) mechanism, where applicable.

Bitkaya will:

  • Provide complainants with relevant contact details.
  • Cooperate fully with any external investigation or review.
  • Implement any binding decisions or corrective measures.

13. Continuous Improvement

  • Escalated complaints and recurring issues are reviewed at management level.
  • Corrective actions are implemented promptly and tracked for completion.
  • Insights from complaints are integrated into:
    • Risk management processes.
    • Staff training programs.
    • Service and product development.

This ensures Bitkaya continually improves its complaint handling and overall client experience.

14. Proportionality and Scalability

Bitkaya applies the principle of proportionality in implementing its Complaints Handling Framework, ensuring that procedures are effective, efficient, and aligned with the company’s size, complexity, and risk profile.

The Regulation on Complaints Handling allows the Central Bank to consider the proportional application of requirements for smaller or less complex institutions. Accordingly, Bitkaya’s complaints-handling structure is designed to meet all regulatory standards while remaining scalable as operations grow.

Scope of Application

Proportionality is reflected in the following aspects of Bitkaya’s complaints management process:

  • Structure: A single designated Complaints Officer fulfills the complaints management function. This role may be combined with other compliance-related duties, provided independence and impartiality are maintained.
  • Documentation: Complaints are recorded using a centralized digital register suited to Bitkaya’s current operational scale (e.g., secure Excel-based or cloud database system). As volumes increase, automation and reporting capabilities will expand accordingly.
  • Reporting and Review: Internal reviews occur semi-annually, with additional ad-hoc reviews if trends or high-risk complaints are identified. This frequency is proportionate to current client volume but will scale up as the client base grows.
  • Resources: Staff awareness and training on complaint recognition and response are conducted periodically, ensuring that all team members handling client interactions understand their obligations without imposing excessive administrative burden.
  • Scalability: Bitkaya’s policy framework, systems, and templates are designed for gradual expansion, allowing seamless adaptation to higher transaction volumes, new jurisdictions, or additional regulatory requirements.

By applying proportionality, Bitkaya ensures regulatory compliance, operational efficiency, and continuous improvement while maintaining the flexibility expected of a small but growing Virtual Asset Service Provider (VASP).

Operating Layer

This policy is implemented through PRC-CPO-001 Client Protection and Operations and the linked PROC-COMP-* procedures and CTRL-COMP-* controls.

It supersedes less specific complaint-handling timelines in the MCT operating layer and coordinates risk, assurance, privacy, employee conduct and regulatory communication through the RMF, ICA, PRIV, EMP and REG frameworks.

Implementing Procedures and Controls

Procedures

Controls

Source Document

  • Document title: Client Compliants Handling Manual
  • Corrected BCMS title: Client Complaints Handling Manual
  • Version: 1.0
  • Status in source document: FINAL
  • Date shown in source document: October 2025
  • Approver shown in change log: Board
  • Exact BCMS approval and effective date: 2026-04-21, taken from the approved PDF metadata because the visible document states only October 2025
  • Permanent approved artifact: Bitkaya Client Compliants Handling Manual v10 Approved.pdf
  • Note: the manual is an internal policy artifact and is not registered as a regulatory source.
  • Coverage note: the CBCS Complaints Handling Regulation (2017) cited by the manual is not yet registered as a BCMS source.

Assurance

  • Design status: implemented from approved Client Complaints Handling Manual version 1.0
  • Operating assurance: pending system-derived assessment
  • Evidence status: complaint channels, register and sample case evidence require confirmation
  • Overall status: implemented design; operating-effectiveness testing pending

History

  • 2026-07-26: Aligned assurance wording with the system-derived Hermes/Odoo result model.
  • 2026-07-26: Registered the approved COMP Manual, established its operating layer and aligned MCT complaint service levels.
  • 2026-07-28: Enriched policy body to full 100% PDF coverage — all 14 sections, every paragraph from the approved manual transcribed.

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