Purpose
Provide clear internal and external escalation and cooperate lawfully with CBCS, the Ombudsman, courts and applicable dispute-resolution bodies, as mandated by sections 10 (Internal Follow-Up and Reporting) and 12 (Escalation Process) of the approved Client Complaints Handling Manual.
Escalation Rights
If a complainant is dissatisfied with Bitkaya’s final response, they may escalate the matter to external bodies, including the Central Bank of Curaçao and Sint Maarten (CBCS), the Ombudsman, the Court of Justice, or an Alternative Dispute Resolution (ADR) mechanism where applicable. Bitkaya will provide complainants with relevant contact details, cooperate fully with any external investigation or review, and implement any binding decisions or corrective measures.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Escalate internally for management-level review | Overdue, high-risk, recurring, systemic, legal, ethical, or regulatory complaints. | Internal escalation log |
| 2 | Inform complainant of external escalation options | If dissatisfied with Bitkaya’s final response: CBCS (Central Bank of Curaçao and Sint Maarten), Ombudsman, Court of Justice, or an Alternative Dispute Resolution (ADR) mechanism where applicable. | Escalation options notice |
| 3 | Provide external body contact details | Provide complainants with relevant contact details for each external body. | Contact information record |
| 4 | Receive and authenticate external requests or referrals | Requests or referrals from CBCS or other competent bodies. | Request authentication record |
| 5 | Preserve the complaint record and coordinate responses | Coordinate authorized, accurate, and timely responses. | Response coordination record |
| 6 | Protect sensitive information | Personal, confidential, privileged, and reporting-sensitive information. | Confidentiality / access-control record |
| 7 | Cooperate fully with external investigations or reviews | Provide full cooperation with any external investigation or review. | Cooperation record |
| 8 | Record external communications and deadlines | Submissions, hearings, decisions, and deadlines. | External communication log |
| 9 | Implement binding decisions or corrective measures | Implement any binding decisions or corrective measures and track closure. | Corrective-action tracker |
| 10 | Provide complaints data to the CBCS upon request | Ensure full regulatory transparency. | CBCS data response record |
| 11 | Assess separate regulatory reporting obligations | Incident, misconduct, or enforcement obligations. | Regulatory reporting assessment |
Records
- Internal escalation and management-level decision
- External contact information provided to complainant (CBCS, Ombudsman, Court of Justice, ADR)
- Authority requests and response approvals
- Cooperation records with external investigations or reviews
- Submissions, decisions, binding decisions implemented, and corrective-action closure
- CBCS data requests and responses
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMP-006 Ensure Complaint Escalations and External Cooperation Are Controlled
History
- 2026-07-28: Enriched with full operational details from PDF sections 10, 12 (external escalation bodies, CBCS/Ombudsman/Court/ADR, cooperation, binding decisions, CBCS data provision).
- 2026-07-26: Created from sections 10-12 of the approved COMP Manual.