Purpose
Maintain accountable safeguarding governance, competence, oversight and risk-based scalability for the protection, handling, safeguarding, recording, and controlled movement of client money and virtual assets. Safeguarding governance must ensure that client asset protection is managed not only as an accounting or custody function, but also as a legal, compliance, operational, and client protection responsibility.
Scope
This procedure applies to all employees, officers, directors, contractors, and relevant third parties involved in client asset handling, wallet operations, payment flows, reconciliations, authorizations, monitoring, or reporting.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Designate the DSO and a documented backup | The DSO oversees client asset protection, reconciliations, and custody integrity. Maintain a role and segregation-of-duties matrix documenting responsibilities for all safeguarding functions. | Role and segregation-of-duties matrix; DSO designation record |
| 2 | Maintain the client-asset inventory | Living register of services, accounts, wallets, providers, systems and risks; updated when new items are introduced. | Client-asset inventory register |
| 3 | Report to management and the Board at least quarterly | Cover segregation and reconciliation performance; safeguarding incidents and near misses; withdrawal and transfer exceptions; unresolved restrictions, holds, or breaks; third-party dependency risk; interaction between safeguarding and compliance controls; and remediation actions. | Quarterly Board reporting |
| 4 | Provide mandatory safeguarding onboarding training | Cover client asset protection principles; AML and CFT integration; safeguarding protocols and escalation procedures. Refresh annually with certification or acknowledgment. | Training, certification and acknowledgment records |
| 5 | Provide enhanced role-specific training | For employees in sensitive roles (finance, custody operations, compliance, IT security), tailored to their safeguarding responsibilities. | Role-specific training records |
| 6 | Implement ongoing awareness initiatives | Reinforce key safeguarding principles, emphasizing clear separation between client assets and Bitkaya’s own assets. | Awareness initiative records |
| 7 | Record training completion and competence | Record training completion, staff acknowledgments and competence assessment results; maintain subject to audit. | Training, acknowledgment and competence assessment records |
| 8 | Review proportionality annually or after significant changes | Triggered by business scale changes, regulatory updates or CBCS guidance, operational or cybersecurity incidents, new custody providers, or new jurisdictions. Head of Risk & Compliance reviews and reports to Board. | Annual proportionality review and Board report |
| 9 | Obtain Board approval for material proportionality adjustments | Covers frequency of reconciliations, staffing allocation, automation thresholds, or other control changes. | Board approval record |
| 10 | Document and approve proportionality decisions | Approved by DSO and Board. Retain justifications, control adjustments and audit evidence for at least five (5) years. | Proportionality decision records with justifications and audit evidence (5-year retention) |
| 11 | Maintain version control log | Record all manual changes, effective dates and approving authorities. Manual updates approved by Board and communicated to all staff. | Version control log |
Records
- Role and segregation-of-duties matrix
- Safeguarding inventory and risk assessment
- Quarterly Board reporting covering segregation, reconciliation, incidents, exceptions, third-party risks and remediation
- Training, acknowledgment, certification and competence assessment records
- Annual proportionality review, Board approval and supporting justifications
- Version control log for manual changes
Relationships
- Policy: POL-SAFU-001 Client Asset Protection and Safeguarding Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-SAFU-001 Ensure Safeguarding Governance Training and Proportionality Are Maintained
History
- 2026-07-26: Created from sections 11-12, 16 and 18 of the approved SAFU Manual.