Purpose
Prevent release of inaccurate, misleading, unbalanced, unauthorized or legally restricted external communications.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Submit final draft and supporting materials | Submit the final draft, intended channel, audience, jurisdiction, release date, claims substantiation and disclosure rationale | Approval package and claims substantiation |
| 2 | Confirm content quality and suitability | Confirm factual accuracy, readability, balance, fee transparency, limitations, target-audience suitability and consistency with actual operating capability | Specialist and Compliance review |
| 3 | Obtain specialist review | Obtain specialist review for AML, sanctions, safeguarding, privacy, complaints, legal, advice, white-paper or regulatory-status content | Specialist and Compliance review |
| 4 | Verify licensing and regulatory claims | Verify that licensing, authorization, registration and supervision claims reflect the current confirmed status | Specialist and Compliance review |
| 5 | Obtain Compliance and management approval | Obtain Compliance approval and required Senior Management or other approval before release | Approval authority and decision |
| 6 | Assign version and publish | Assign a version, owner, effective date and next review date and publish only the approved version | Approved and released versions |
| 7 | Verify released communication | Verify the released communication against the approved version and record channel and publication evidence | Publication, correction and withdrawal evidence |
| 8 | Retain records | Retain the draft, evidence, comments, approvals, final version, release evidence and subsequent correction or withdrawal history | Publication, correction and withdrawal evidence |
Compliance Review Triggers (Section 7 of the Approved Manual)
No external communication relating to products, services, onboarding, risk disclosures, restrictions, or operational capabilities may be published without appropriate internal review. Compliance review is required where content touches on:
- onboarding and due diligence expectations;
- client acceptance or approval language;
- sanctions, legal, or compliance restrictions;
- safeguarding or asset access language;
- complaints or escalation channels;
- regulatory status or reporting obligations; or
- representations about the certainty, speed, or permissibility of transactions or withdrawals.
Recordkeeping Requirement
Final versions must be retained in accordance with Bitkaya’s recordkeeping requirements. The retention package includes the draft, evidence, comments, approvals, final version, release evidence and subsequent correction or withdrawal history.
Proportionality in Approval
For a small VASP such as Bitkaya, communication approval may rest with a single Compliance Officer and one member of management. Internal approval workflows are scaled to operational size; Compliance and Senior Management jointly approve key public communications. For low-risk products and audiences, streamlined reviews apply, while communications about higher-risk or innovative virtual asset services undergo enhanced compliance scrutiny.
Exceptions and Escalation
No external communication within scope may be released without the required approval. Unresolved factual, licensing, jurisdictional, confidentiality or disclosure concerns block release.
Records
- Approval package and claims substantiation
- Specialist and Compliance review
- Approval authority and decision
- Approved and released versions
- Publication, correction and withdrawal evidence
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMM-005 Ensure External Communications Are Approved Versioned and Retained
History
- 2026-07-26: Created from sections 5-7 and 10-11 of the approved COMM Manual.