Purpose
Draft communications that are accurate, understandable, balanced and appropriate to the channel, audience and intended use.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Define audience and communication parameters | Define the audience, jurisdiction, channel, purpose, product or service, intended action and communication owner | Communication brief and target-audience assessment |
| 2 | Obtain current substantiated facts | Obtain current substantiated facts, fees, features, limitations, operating conditions and risk information | Source facts and claims substantiation |
| 3 | Use plain language and distinguish content types | Use plain language and distinguish facts, opinions, education, comparisons and promotional claims | Draft and channel-specific checklist |
| 4 | Verify website and white-paper content | For websites and white papers, verify accuracy, currency, ownership, approval needs and applicable regulatory authorization | Draft and channel-specific checklist |
| 5 | Apply social-media rules | For social media, prohibit guaranteed-profit, risk-free, artificial-urgency and unsupported comparison claims and use approved disclaimers | Images, comparisons and proposed disclaimers |
| 6 | Apply advertising rules | For advertising, give risks and benefits balanced prominence and avoid misleading imagery, slogans or wealth implications | Images, comparisons and proposed disclaimers |
| 7 | Apply document and email rules | For documents and emails, explain relevant control dependencies, information requests, restrictions and disclosure limitations | Draft and channel-specific checklist |
| 8 | Preserve substantiation and route for review | Preserve claims substantiation and route the draft through the required review workflow | Submission for approval |
Channel-Specific Rules (Section 5 of the Approved Manual)
Website & Whitepapers:
- Must be factually accurate, updated regularly, and approved by Compliance.
- Whitepapers (if Bitkaya issues tokens) require Central Bank approval (Art. 46).
Social Media:
- Prohibited: “Guaranteed profits,” “Risk-free trading,” “Limited time double-your-money.”
- Allowed: Educational posts, service updates, factual comparisons (with references).
- Always add disclaimers: e.g., “#CryptoRisks notguaranteed.”
Advertising:
- Must be clear and balanced — same prominence for risks and benefits.
- No promises of fixed returns.
- Images and slogans must not mislead (e.g., using luxury cars to suggest wealth creation).
Client Documents & Emails:
Client documents, onboarding materials, transactional messages, and emails must make clear that:
- onboarding and transaction processing are subject to legal, compliance, and sanctions controls;
- additional information or documentation may be required depending on the client’s risk profile or activity;
- Bitkaya may delay, restrict, refuse, block, or report certain activity where required by law or internal control procedures; and
- Bitkaya may be legally restricted in what it can disclose about certain reviews, escalations, or restrictions.
Standard language should be reviewed by Compliance where the message touches on onboarding, due diligence, restrictions, escalation, safeguarding, or legal reporting matters.
Records
- Communication brief and target-audience assessment
- Source facts and claims substantiation
- Draft and channel-specific checklist
- Images, comparisons and proposed disclaimers
- Submission for approval
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMM-002 Ensure Channel Communications Are Accurate Clear and Balanced
History
- 2026-07-26: Created from sections 3 and 5 of the approved COMM Manual.