Purpose
Maintain current finance and tax obligations, ownership, deadlines, authorities, systems, advisers, control frequencies and proportionality decisions.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Maintain obligation inventory | Cover corporate records, annual accounts, CBCS financial reporting, CIT, TOT, wage tax, social security, withholding analysis, audit, publication and authority requests. Reflect that Bitkaya operates as a B.V. under Book 2 of the Curaçao Civil Code. | |
| 2 | Record obligation attributes | For each obligation record authoritative source, reporting period, deadline, filing channel, preparer, reviewer, approver, payment authority and evidence location. Include CIT annual return (due within 6 months of year-end), provisional CIT returns and quarterly advance payments, TOT monthly filings, wage tax monthly filings, and SVB monthly declarations and contributions. | |
| 3 | Confirm rates, thresholds, exemptions | Confirm before each annual cycle and after announced legal or authority change. Specific items: CIT standard rate 22% and e-zone/export regime incentives (3%/0% subject to approval and substance); TOT 6% on domestic supplies with exemptions for exported services, certain financial services, e-zone companies; wage tax progressive up to ~46.5%; social security contributions (AOV/AWW pensions, AVBZ long-term care, BVZ health insurance, SVB); large-company audit thresholds (>20 employees, >ANG 5M assets, >ANG 10M turnover); statutory record retention 5 years (subject to longer VASP/AML/safeguarding periods). | |
| 4 | Assign owners and document segregation | Assign primary and backup owners; document segregation between preparation, review, approval, payment, reconciliation and evidence custody. For a small VASP, dual control and segregation of duties may be simplified but must always ensure integrity and accountability. | |
| 5 | Register and review systems access | Register finance, payroll, banking, filing and evidence systems; review access at least annually. Leverage technology (automated bookkeeping, payroll integration, cloud-based reporting) for efficiency and transparency. Compliance staffing follows a “fit-for-size” model with cross-trained key functions rather than duplication. | |
| 6 | Assess external expertise needs | Assess whether external accounting, tax, payroll, legal or audit expertise is required; document scope, independence and deliverables. Internal audit may be replaced initially by external review from a qualified accounting professional until growth justifies a dedicated internal function. | |
| 7 | Review proportionality | Review annually and after growth, licensing, product, organization, system or risk change; document any reduced frequency and compensating control. Three core dimensions: (1) Size and Complexity — limited transaction volume, simplified structure, emerging operational scale; (2) Risk Exposure — controls tailored to inherent risk of client base, product type, transaction profile; (3) Growth and Maturity — governance/oversight progressively strengthening per CBCS expectations and internal growth indicators. | |
| 8 | Protect statutory frequencies | Do not reduce any statutory filing, payment, reconciliation or reporting frequency through a proportionality decision. Under proportionality, controls (e.g., financial reconciliations, supplier due diligence, tax compliance checks) may be quarterly instead of monthly, but statutory monthly TOT and wage tax filings remain mandatory. | |
| 9 | Obtain Board approval for changes | Obtain Board approval for material changes; update FIN, REG, ICA and RMF relationships and calendars. All proportionality decisions (scope reductions, control frequency, reporting simplifications) must be documented and justified within the internal compliance framework. Changes must be reflected in the compliance manual, board minutes, or policy updates. | |
| 10 | Monitor growth indicators | Monitor transaction volume and customer base expansion; employment growth beyond 10 FTEs; asset or turnover exceeding ANG 10M thresholds; CBCS licensing updates or supervisory feedback. Upon reaching thresholds, reassess the proportional implementation plan and adopt additional controls (periodic internal audits, more formalized reporting, expanded management oversight). | |
| 11 | Benchmark compliance maturity | Benchmark periodically against CBCS supervisory standards and peer best practices for small VASPs to ensure the framework remains robust, efficient, and fit-for-purpose as the company scales. |
Evidence
- Finance and tax obligation register and calendar
- Responsibility and segregation matrix
- Authoritative-source and rate confirmation
- System and access inventory
- Adviser and auditor appointments
- Annual proportionality assessment and Board approval
Escalation
Escalate an unidentified owner, uncertain legal basis, missed or at-risk deadline, unresolved threshold, incompatible duty or unsupported proportionality reduction to Compliance and Management immediately.
Relationships
- Policy: POL-FIN-001 Finance and Tax Compliance Manual
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-FIN-001 Ensure Finance Tax Governance Calendar and Proportionality Are Current
History
- 2026-07-26: Created from sections 1, 2, 5 and 6 of the approved FIN Manual.