Purpose
Screen clients, counterparties, wallets, transactions and related parties for sanctions exposure and escalate unresolved or confirmed matches before activity proceeds.
Scope
This procedure applies before onboarding, before relationship activation, during periodic review, after sanctions list updates, upon trigger events and before relevant transaction execution, settlement, release or completion.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Identify screening scope | Identify all parties and identifiers requiring screening: client, beneficial owners, directors, authorized representatives, signatories, intermediaries, VASP counterparties, wallet addresses, blockchain identifiers, fiat payment counterparties, and any other linked party where sanctions exposure may arise | Screening scope record |
| 2 | Screen applicable parties | Screen clients, UBOs, directors, representatives, intermediaries, VASP counterparties, wallet addresses, blockchain identifiers and fiat payment counterparties | Screening report |
| 3 | Apply screening timing | Screen before onboarding, before activation, during periodic review, after trigger events, after sanctions-list refresh, and before execution, settlement, release or completion of relevant transactions | Screening log |
| 4 | Use reliable tools and lists | Cover at minimum UN and EU sanctions lists. Where applicable to Bitkaya’s exposure, also screen OFAC, CFATF, Curaçao/Kingdom/local sanctions or restricted lists, and internal restricted-party or restricted-jurisdiction lists | Sanctions-list coverage record |
| 5 | Classify prohibited jurisdictions | Classify jurisdictions subject to comprehensive UN, EU, applicable Kingdom sanctions, or any regime legally prohibiting or materially restricting services as Prohibited Jurisdictions — outside Bitkaya’s risk appetite | Prohibited-jurisdiction decision |
| 6 | Enforce prohibition | Do not establish or maintain relationships, process transactions, provide wallet services, facilitate transfers, or provide services where doing so would violate applicable sanctions legislation or involve a prohibited jurisdiction. EDD or management approval cannot override the prohibition | Refusal/blocking record |
| 7 | Escalate prohibited-jurisdiction exposure | Where a client, UBO, counterparty, transaction, wallet, or relationship becomes associated with a prohibited jurisdiction, escalate immediately to Compliance for assessment and implementation of required restrictive measures (blocking, freezing, refusal, termination, reporting, notification) | Escalation record |
| 8 | Review and clear alerts | Review alerts promptly; document identifiers checked, sources used, investigation, and false-positive rationale where cleared | Alert disposition |
| 9 | Block unresolved alerts | Prevent onboarding, settlement, wallet setup, transfer, payment, release or completion while a material alert remains unresolved until appropriately resolved or escalated | Hold/stop record |
| 10 | Apply restrictive measures | Where a sanctions alert is confirmed as a true match, immediately apply legally required restrictive measures (blocking, freezing, rejecting, refusing, restricting). Escalate true matches, prohibited-jurisdiction exposure and unresolved alerts to Compliance without delay | Restrictive measure record |
| 11 | Assess FIU and CBCS obligations | Apply required blocking/freezing/rejecting/refusing/terminating/reporting/notification measures and separately assess FIU Curaçao and CBCS reporting or notification obligations | Reporting evidence |
| 12 | Retain screening records | Retain results, investigation, timing, owner, rationale, restrictive measures, escalation decisions, and reporting or notification records per Bitkaya’s recordkeeping requirements | Retained screening file |
Evidence
- screening report
- alert disposition
- false-positive rationale
- restrictive measure record
- escalation or reporting evidence
- sanctions-list coverage and refresh record
- prohibited-jurisdiction decision
Relationships
- Policy: POL-AML-001 AML CTF CPF Compliance Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Controls: CTRL-AML-003 Ensure Sanctions Screening and Restrictive Measures Operate, CTRL-AML-005 Ensure FIU Reporting and Case Escalation Are Completed
- Manual coverage: sections 4.3, 4.4 and 5.4.
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Design status: implemented from approved AML/CTF/CPF Compliance Manual version 2.2
History
- 2026-07-26: Expanded lifecycle timing, list coverage, prohibited-jurisdiction treatment and FIU/CBCS decision evidence after a full manual rescreen.
- 2026-07-26: Created from the approved AML/CTF/CPF Compliance Manual version 2.2.