Purpose
Ensure payments, receipts, reimbursements, settlements, balance movements and exceptions are legitimate, authorized, segregated, reconciled and subject to all applicable restrictions.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Require approved business purpose | Require an approved business purpose, valid counterparty, supporting document, account classification and tax treatment for each material movement. Financial records must be sufficiently detailed and reliable to support documentation of holds, restrictions, reversals, or exceptions and traceability of decisions affecting payments, receipts, settlements, and financial reporting. | |
| 2 | Verify counterparty details | Verify payee or payer details against trusted records and apply enhanced verification to new or changed bank details, unusual instructions and high-risk counterparties. | |
| 3 | Confirm budget or authority | Confirm budget or authority and apply preparation, approval and release separation appropriate to the amount and risk. For a small VASP, dual control and segregation of duties may be simplified but must always ensure integrity and accountability. Segregation of duties in payments, approvals, reconciliations, and reporting must be ensured. | |
| 4 | Check for restrictions | Check whether the movement involves a client asset, safeguarding restriction, sanctions match, unusual-activity review, fraud concern, legal hold, disputed item or regulatory escalation. Finance and tax compliance must operate consistently with Bitkaya’s AML/CTF/CPF, sanctions, and safeguarding controls. | |
| 5 | Stop and refer on restriction | Stop processing and refer the matter to the designated owner when any restriction or unresolved concern applies; Finance must not override the control process. Where a payment, receipt, invoice, reimbursement, settlement, or balance movement is subject to legal restriction, unusual activity review, sanctions concern, fraud concern, or compliance escalation, finance processing must not override the applicable control process. | |
| 6 | Execute through authorized channels | Execute approved movements through authorized accounts and channels and preserve the instruction, approvals and execution reference. | |
| 7 | Reconcile executed movements | Reconcile executed movements to bank, payment, client, safeguarding and ledger records and investigate rejected, duplicate, reversed, unmatched or stale items. Under proportionality, financial reconciliations may be performed quarterly instead of monthly, consistent with proportional monitoring principles. | |
| 8 | Record exceptions and overrides | Record every exception, override request, control break and compensating control with owner, severity, due date and approval. Exceptions and anomalies must be escalated directly to management for prompt review. 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 | Escalate material or aged matters | Escalate material or aged matters to Compliance and Management and assess REG, AML, SAFU, ABC and RMF reporting implications separately. Coordinate with Compliance where unusual activity, restricted items, or reporting questions arise. | |
| 10 | Review access and exception trends | Review access, limits, authorized signatories, overrides and exception trends at least quarterly and after personnel, bank, provider or system change. Review control weaknesses and recurring finance exceptions as part of continuous improvement. |
Evidence
- Payment or receipt request and source document
- Counterparty and bank-detail verification
- Approval and release audit trail
- Restriction and compliance clearance where applicable
- Bank, payment, safeguarding and ledger reconciliation
- Exception, override and aged-item register
- Access, limit and signatory review
Relationships
- Policy: POL-FIN-001 Finance and Tax Compliance Manual
- Safeguarding process: PRC-CPO-001 Client Protection and Operations
- AML process: PRC-FCI-001 Financial Crime and Integrity
- Control: CTRL-FIN-006 Ensure Finance Movements Reconciliations and Exceptions Are Controlled
History
- 2026-07-26: Created from sections 2.2, 3.4, 4, 4.4, 5.4 and 6.3 of the approved FIN Manual.