Purpose
Identify inaccurate, misleading, inconsistent, unauthorized or restricted communications and correct them promptly.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Maintain monitoring population | Maintain a risk-based monitoring population of websites, advertisements, social media, campaigns, onboarding materials, client messages and standard documents | Quarterly population, sample and test results |
| 2 | Select and document proportional sample | Select and document a proportional sample at least quarterly, increasing scope for high-risk or innovative services and material change | Quarterly population, sample and test results |
| 3 | Compare content with approved version | Compare published or delivered content with the approved version, substantiation, required disclosures and current operating and regulatory facts | Finding and impact assessment |
| 4 | Record findings and impact | Record findings, severity, audience, duration, client impact, recurrence and possible legal, conduct, privacy, sanctions or reporting implications | Finding and impact assessment |
| 5 | Remove, suspend or correct content | Remove, suspend or correct material content promptly and preserve the original and corrected versions | Original, corrected and withdrawn content |
| 6 | Escalate serious or recurring breaches | Escalate serious or recurring breaches to Compliance, Senior Management, the Board and relevant control owners | Escalation and reporting decision |
| 7 | Assess remediation and reporting actions | Assess client notification, complaint handling, remediation, disciplinary, incident and regulatory-reporting action | Escalation and reporting decision |
| 8 | Track corrective action to closure | Track corrective action to closure and verify effectiveness | Corrective action and closure evidence |
Monitoring Scope (Section 8 of the Approved Manual)
Bitkaya must monitor published and operational communication to identify:
- misleading language;
- inconsistent statements;
- inappropriate promises;
- weak disclosures; or
- communications that could conflict with legal, sanctions, or compliance obligations.
Proportional Monitoring Approach (Section 11.3)
Communication monitoring is performed quarterly, rather than daily, reflecting the current scale of marketing activity. Proportional sample testing of advertisements, website updates, and client communications is used to confirm ongoing compliance. The Compliance Officer reports findings to management, and the frequency or scope of monitoring may increase as the business scales.
Breach Escalation (Section 9 of the Approved Manual)
Misleading, incomplete, or inappropriate communication may expose Bitkaya to legal, regulatory, client protection, and reputational risk. Where a communication issue also touches on sanctions, unusual activity review, legal restrictions, or internal compliance handling, the matter must be escalated and assessed in coordination with the relevant control functions. Any staff communication that inappropriately discloses, confirms, or implies the existence of a sanctions review, unusual activity assessment, or internal reporting process may constitute a serious control breach and must be treated accordingly.
Records
- Quarterly population, sample and test results
- Finding and impact assessment
- Original, corrected and withdrawn content
- Escalation and reporting decision
- Corrective action and closure evidence
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMM-006 Ensure Communications Are Monitored and Breaches Corrected
History
- 2026-07-26: Created from sections 8-9 and 11 of the approved COMM Manual.