Purpose
Handle client orders fairly, promptly, confidentially and in the client’s interests while applying required legal, compliance, sanctions, fraud, safeguarding and operational restrictions, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 section 4 and section 11.1.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Record order receipt time, client instruction, asset, size, venue options, settlement path and persons involved | Client orders must be managed with integrity, efficiency, confidentiality and appropriate control discipline; order handling records must be sufficient to demonstrate the timing of the order, the actions taken, the persons involved, any restrictions or delays applied and the reason for any escalation, hold or refusal | MCT 4.2 |
| 2 | Evaluate price, speed, execution and settlement likelihood, order size, market conditions and relevant venue or liquidity-provider factors | In determining best execution, the firm considers price, speed, likelihood of execution and settlement, order size and prevailing market conditions | MCT 4.1 Execution Factors |
| 3 | Route and execute fairly and promptly without favoring employees, affiliates or selected clients | Orders may be routed through different trading venues, exchanges or liquidity providers, but only where this aligns with the client’s best interests | MCT 4.1 Use of Venues |
| 4 | Screen for unusual, inconsistent, restricted or higher-risk order, payment, wallet, settlement and transaction characteristics | Trading activity must be consistent with Bitkaya’s AML/CTF/CPF, sanctions, safeguarding and client protection obligations, including review of elevated-risk trading patterns, suspicious off-ramping and on-ramping behaviour, unusual transaction activity, sanctions or wallet exposure concerns and any other circumstances requiring escalation before execution, settlement or release of assets | MCT 4 intro |
| 5 | Place a documented hold, restriction, escalation or refusal where unresolved legal, sanctions, fraud, safeguarding, AML or operational concerns remain | Bitkaya is not required to proceed with execution, settlement, transfer or release where legal, compliance, sanctions, fraud, safeguarding or operational concerns remain unresolved; where an order, payment flow, wallet destination, transaction pattern or client instruction presents unusual, inconsistent, restricted or higher-risk characteristics, the matter must be reviewed and, where necessary, escalated before further action is taken | MCT 4.2 |
| 6 | Preserve confidentiality and do not disclose internal compliance conclusions in breach of anti-tipping-off or legal restrictions | MCT 5.2 | |
| 7 | Record execution, delay, hold, escalation, refusal, release and settlement rationale sufficiently to reconstruct handling | MCT 4.2 | |
| 8 | Inform clients of execution policies and material limitations through approved disclosures, ensuring transparency in how their trades are handled | MCT 4.1 Disclosure | |
| 9 | Review execution quality regularly through risk-based trade samples and adjust venues, controls or procedures where needed | Execution quality will be reviewed regularly and adjustments made to maintain high standards of client protection (MCT 4.1 Monitoring). High-risk clients and transactions are subject to stronger review and escalation thresholds; suspicious activity identified through trading or settlement behaviour is escalated appropriately; legal or sanctions restrictions are respected before execution or release; control decisions are documented; and management information captures emerging risks, recurring issues and remediation actions | MCT 11.1 |
Exceptions and Escalation
Fair and timely handling does not require execution or release while a material restriction remains unresolved. Any override requires documented authority and legal permissibility.
Records
- Order and handling audit trail
- Execution-factor and venue decision
- Restriction, hold, escalation or refusal rationale
- Settlement and release evidence
- Client execution disclosure
- Execution-quality review and remediation
Relationships
- Policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-MCT-003 Ensure Best Execution and Order Handling Are Controlled
- Related AML process: PRC-FCI-001 Financial Crime and Integrity
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Frequency: per order with regular risk-based execution review
History
- 2026-07-26: Created from section 4 and section 11.1 of the approved MCT Manual.