Purpose
Provide complete, accurate and controlled management reporting and authority responses, support assurance and ensure finance and tax weaknesses are remediated.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Produce monthly management accounts | Produce monthly management accounts and finance reporting from reconciled records and identify material variances, restricted items, unresolved breaks, unsupported movements, aged exceptions, overrides and dependencies. 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. | |
| 2 | Review and escalate material matters | Provide Finance and Management review and escalate material matters to Compliance, the Board or relevant committee. 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. | |
| 3 | Log authority requests | Log each tax, SVB, CBCS, auditor or other authorized request with scope, authority, deadline, owner, reviewer, approver and confidentiality restrictions. Proactive communication with the Curaçao Tax Inspectorate and the Social Insurance Bank (SVB) is essential to avoid penalties and establish a compliant reputation. Authorities can request information during audits or inspections; non-cooperation increases risk of penalties and director liability. | |
| 4 | Preserve records and coordinate | Preserve the requested period and records and coordinate with Compliance and Legal where the request overlaps client assets, AML, sanctions, suspicious activity, investigations, privacy or privileged matters. When responding to tax authority inquiries, audits, or requests, Bitkaya must ensure that disclosures remain accurate, complete, and consistent with other legal and regulatory obligations. Where requested information overlaps with client asset safeguarding, compliance investigations, sanctions matters, suspicious activity review, or other restricted matters, Finance must coordinate with Compliance and Legal before responding. | |
| 5 | Compile response | Compile the response from controlled records, reconcile totals and facts to prior submissions and document explanations for differences. | |
| 6 | Obtain review and approval | Obtain independent review and authorized approval before release and use the required secure channel. | |
| 7 | Retain request and response evidence | Retain the request, response, approvals, delivery evidence, follow-up and final closure. 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. | |
| 8 | Support testing and audit | Support second-line testing, external review and audit with complete evidence while preserving independence and access control. Internal audit functions may be replaced initially by an external review from a qualified accounting professional until growth justifies a dedicated internal function. SVB audits focus on employee records, contracts, and salary slips. | |
| 9 | Record findings and assign remediation | Record findings, late filings, inaccuracies, unsupported balances, repeat exceptions and control failures; assign root cause, action, owner and due date. Review control weaknesses and recurring finance exceptions as part of continuous improvement. | |
| 10 | Verify remediation and feed lessons | Verify remediation independently, report overdue or material actions and feed lessons into procedures, training, systems, calendars and proportionality review. Apply a tiered escalation and review process to address compliance or tax irregularities, ensuring prompt remediation and transparency. Benchmark compliance maturity periodically against CBCS supervisory standards and peer best practices for small VASPs. |
Evidence
- Monthly management accounts and review
- Finance exception and escalation reporting
- Authority and auditor request log
- Response pack, reconciliation, review and approval
- Secure delivery and closure evidence
- Control test and audit evidence
- Findings, root cause, remediation and closure verification
- Training and annual improvement review
Relationships
- Policy: POL-FIN-001 Finance and Tax Compliance Manual
- Reporting process: PRC-RSA-001 Resilience Systems and Assurance
- Assurance process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-FIN-007 Ensure Authority Requests Reporting Assurance and Remediation Are Managed
History
- 2026-07-26: Created from sections 4.4, 5 and 6 of the approved FIN Manual.