Purpose
Maintain accountable ownership, communication standards and a controlled library of approved statements, disclosures and regulatory representations.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Assign Compliance ownership and identify content owners | Identify content owners, reviewers, approval authorities and authorized spokespersons | Roles and approval-authority matrix |
| 2 | Maintain a communication inventory | Cover active channels, audiences, owners, products, services and jurisdictions | Communication and channel inventory |
| 3 | Maintain approved wording | Maintain approved wording for risk disclosures, fees, service limitations, onboarding, complaints, privacy, safeguarding and operational restrictions | Approved-wording and disclosure library |
| 4 | Record source and approval metadata | Record the source, approval, effective date, review date and permitted use for every standard statement | Approved-wording and disclosure library |
| 5 | Verify regulatory-status and licensing language | Verify with Compliance before approval and after any legal or status change | Regulatory-status verification |
| 6 | Remove or quarantine obsolete wording | Remove or quarantine obsolete, unsubstantiated or conflicting wording | Change, withdrawal and review history |
| 7 | Communicate material changes | Communicate material changes to affected content owners and require updates to live content | Change, withdrawal and review history |
| 8 | Review framework and approved wording | Review the framework and approved wording at least annually and after material change | Change, withdrawal and review history |
Approved Wording Library Content
The approved-wording library must include, at minimum, the standard statements and templates defined in Section 10 of the approved manual:
- Risk Disclaimer for Ads: “Virtual assets are high-risk and volatile. You may lose your entire investment. Bitkaya is licensed under the Landsverordening toezicht virtuele activa dienstverleners and supervised by the Central Bank of Curaçao and Sint Maarten.”
- Website Footer: “Bitkaya N.V. is licensed and supervised by the Centrale Bank van Curaçao en Sint Maarten as a Virtual Asset Service Provider (VASP). Investments in virtual assets involve significant risks, including volatility, regulatory changes, and possible total loss of capital.”
- Email Signature Disclaimer: “This communication is for informational purposes only and does not constitute financial advice. Virtual assets are volatile and may result in a total loss of funds.”
- Mandatory Risk Statements (Section 4): Volatility, Loss of Capital, Regulatory Changes, Technology Risks, AML/CTF Monitoring — each with the exact approved wording from the manual.
- Social Media Disclaimers: e.g., “#CryptoRisks notguaranteed.”
Proportionality in Wording Governance
For a small VASP such as Bitkaya, approval may rest with a single Compliance Officer and one member of management. Use of pre-approved templates, disclaimers, and concise communication reduces operational burden while ensuring compliance with Articles 42, 45, and 46 of the LvT VAD.
Records
- Roles and approval-authority matrix
- Communication and channel inventory
- Approved-wording and disclosure library
- Regulatory-status verification
- Change, withdrawal and review history
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMM-001 Ensure Communication Standards and Approved Wording Are Current
History
- 2026-07-26: Created from sections 1-3, 7 and 10-11 of the approved COMM Manual.