Train Staff Review Proportionality and Scale Controls

Purpose

Maintain communication competence and ensure controls remain proportionate, effective and scalable.

Steps

#	Action	Details	Evidence
1	Identify relevant staff	Identify staff who create, review, approve, publish or deliver client and public communications	Role-based training needs analysis
2	Provide foundational and role-specific training	Provide foundational training to new relevant staff and role-specific training to Marketing, Client Service, Onboarding, Operations and Compliance	Training materials, attendance and assessment
3	Cover required training topics	Cover misleading claims, risk prominence, onboarding uncertainty, restrictions, confidentiality, anti-tipping-off, approved wording and approval triggers	Training materials, attendance and assessment
4	Assess understanding and address gaps	Assess understanding and address missed or failed training	Training materials, attendance and assessment
5	Review monitoring and incidents for implications	Review quarterly monitoring, complaints, incidents, breaches, regulatory change and business growth for training and control implications	Annual proportionality and scalability review
6	Assess proportionality annually	At least annually, assess whether review depth, sample size, approval layers, systems and reporting remain proportionate to products, clients, channels, jurisdictions and risk	Annual proportionality and scalability review
7	Scale controls where warranted	Increase automation, monitoring frequency, specialist review or management oversight where scale or risk warrants it	Improvement action and closure evidence
8	Report findings and track actions	Report material findings and improvement actions to Senior Management and track completion	Management report and decisions

Training Content Requirements (Section 8 of the Approved Manual)

Training should ensure that staff understand:

what they may and may not say about onboarding, restrictions, escalation, and internal reviews;
how to communicate delays or restrictions appropriately;
the importance of avoiding anti-tipping-off breaches;
when standard wording must be used; and
when Compliance approval is required before sending or publishing content.

Proportionality in Training (Section 11.3)

Targeted compliance training focuses on staff directly engaged in client communication, marketing, and onboarding. Frequency and depth of training are proportionate to the risk exposure of each function; new employees receive foundational training, while marketing and client service staff receive more detailed sessions.

Proportionality Review (Section 11.4)

Periodic proportionality reviews ensure controls remain aligned with regulatory expectations and organizational capacity. For a small VASP such as Bitkaya:

Communication approval may rest with a single Compliance Officer and one member of management.
Monitoring and reporting cycles may be less frequent but must remain evidence-based and documented.
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.
As operations scale, the system must adapt to include automated review tools, more frequent audits, and layered management oversight.

As Bitkaya expands its services, client base, or jurisdictions, the proportional approach allows the compliance framework to evolve, moving from basic controls to more sophisticated review, automation, and reporting systems.

Records

Role-based training needs analysis
Training materials, attendance and assessment
Annual proportionality and scalability review
Management report and decisions
Improvement action and closure evidence

Relationships

History

2026-07-26: Created from sections 8 and 11 of the approved COMM Manual.

BCMS

Explorer