Purpose
Maintain complete, accurate and traceable books and records and perform a controlled financial close that supports management, tax, safeguarding, audit and regulatory reporting.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Record transactions from source documents | Record each transaction from an authorized source document with date, counterparty, purpose, amount, currency, account, tax treatment and approval reference. Financial records must be sufficiently detailed and reliable to support: statutory accounting and tax compliance; safeguarding and segregation controls; reconciliation of client and corporate positions; investigation of unusual or restricted transactions; audit and regulatory review; documentation of holds, restrictions, reversals, or exceptions; and traceability of decisions affecting payments, receipts, settlements, and financial reporting. | |
| 2 | Maintain chart of accounts | Maintain a controlled chart of accounts and separate client, safeguarding, corporate, tax, payroll, suspense and intercompany positions as applicable. Accounting standards follow Dutch GAAP, proportionally adapted to the company’s scale (e.g., simplified disclosures, limited segment reporting). Alignment between financial accounts and tax accounts is required. | |
| 3 | Reconcile accounts | Reconcile bank, payment, custody, client, corporate, tax, payroll and material balance-sheet accounts at the frequency required for reliable reporting and filing. Under proportionality, financial reconciliations may be performed quarterly instead of monthly, consistent with proportional monitoring principles; however, statutory monthly filing, reporting, and payment obligations are not reduced. | |
| 4 | Investigate differences and exceptions | Investigate differences, unsupported entries, unusual movements, stale items, overrides and restricted balances; assign owner and due date. Exceptions and anomalies must be escalated directly to management for prompt review. | |
| 5 | Apply close controls | Apply documented cut-off, accrual, valuation, foreign-exchange, classification and journal-entry controls. Where financial activity is linked to a client relationship, client asset flow, unusual transaction review, sanctions issue, safeguarding event, or regulatory reporting matter, finance records must support cross-reference to the relevant operational or compliance documentation. | |
| 6 | Reconcile tax accounts to GL | Reconcile tax accounts to the general ledger and record differences between financial and tax treatment. | |
| 7 | Prepare and review close | Prepare and independently review the monthly close checklist, trial balance, reconciliations and management accounts. For a small VASP, dual control and segregation of duties may be simplified but must always ensure integrity and accountability. | |
| 8 | Report unresolved breaks and exceptions | Report unresolved breaks, unusual or unsupported payments, restricted items, aged exceptions, overrides, dependencies and material control issues. Monthly management accounts and internal finance reporting should not only reconcile to tax filings and statutory reporting, but also support visibility over restricted items, outstanding reconciliations, unusual payment events, unresolved exceptions, and material control issues affecting financial integrity. Where relevant, internal finance reporting should capture: unresolved breaks or discrepancies; unusual or unsupported payments or receipts; restricted transactions or balances; aged exceptions; control overrides; material third-party dependency issues; and items requiring escalation to Compliance, Management, or the Board. | |
| 9 | Lock closed periods | Lock or otherwise protect closed periods and control post-close adjustments through documented approval. Technology solutions (e.g., automated bookkeeping, payroll integration, and cloud-based reporting) should be leveraged to ensure efficiency and transparency. | |
| 10 | Retain books and records | Retain books, invoices, contracts, calculations, approvals, statements, reconciliations and correspondence for the longest applicable retention period. Record retention remains at the statutory 5 years, though documentation can be digital if securely stored and retrievable. Where records are also relevant to AML/CTF/CPF, safeguarding, audit, legal, regulatory, or dispute-related matters, they may need to be retained for a longer period in accordance with Bitkaya’s wider recordkeeping obligations. Finance must coordinate with Compliance, Legal, and Management where uncertainty exists over whether destruction, deletion, or closure of records is appropriate. |
Evidence
- Chart of accounts and accounting policies
- Source documents and ledger entries
- Monthly close checklist and trial balance
- Account, bank, tax and client-position reconciliations
- Journal approvals and post-close adjustment log
- Management accounts and exception report
- Retention and legal-hold records
Escalation
Escalate material unexplained differences, missing records, suspected fraud, restricted or unusual activity, safeguarding breaks, late close or unreliable reporting to Finance, Compliance and Management before filing or payment.
Relationships
- Policy: POL-FIN-001 Finance and Tax Compliance Manual
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-FIN-002 Ensure Books Records and Financial Close Are Complete and Accurate
- Accounting system: SYS-FIN-001 Odoo Accounting ERP
- Implementation SOP: PUB-FIN-001 Bitkaya Accounting Treatment in Odoo SOP
History
- 2026-07-26: Created from sections 2.2, 4 and 6.3 of the approved FIN Manual.
- 2026-07-26: Added the Odoo Accounting Memorandum as the subordinate implementation SOP.