Purpose
Ensure every client-asset movement is properly recorded, traceable, authenticated, authorized, screened, documented and permitted. Client money movements must be supported by appropriate instructions and documentation, consistent with the client relationship and applicable control requirements, subject to authorization by designated personnel, and restricted or escalated where legal, sanctions, fraud, compliance, or safeguarding concerns exist.
Scope
Applies to all receipts, payments, withdrawals, transfers and disbursements of client money and client virtual assets.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Verify the client, instruction, asset, amount, source, destination and supporting records | All receipts and payments of client money promptly recorded with: date of transaction; unique client identifier; amount received or disbursed; and transaction reference number. | Client instruction, identity and authentication records; transaction recording with date, client identifier, amount and reference |
| 2 | Verify wallet ownership and destination controls | Verify wallet ownership, address whitelisting or destination controls where applicable to client virtual asset transfers. | Destination and wallet verification records |
| 3 | Apply sanctions, fraud, and risk-based screening | Apply sanctions and wallet exposure screening, fraud review, unusual-activity review and risk-based transaction review to all client VA transfers and client money movements. | Screening, sanctions, wallet-exposure and risk review records |
| 4 | Apply maker-checker or dual-authorization processes | Enforce role separation for elevated-risk movements. Withdrawals supported by appropriate documentation and authorized by designated personnel; client money only used for purposes expressly permitted under client agreements and applicable regulations. | Maker-checker or dual-authorization records |
| 5 | Confirm authentication, authorization, and permissibility | Confirm request is properly authenticated and authorized; destination is permitted under Bitkaya’s control framework; transaction not subject to legal, sanctions, compliance, fraud, or safeguarding restriction; supporting records complete; elevated-risk features reviewed and escalated where required. | Authorization, permissibility and review records |
| 6 | Do not proceed where unresolved restrictions exist | Do not proceed with client money movement where unresolved sanctions concern, legal restriction, or material compliance alert exists. Do not proceed with client VA transfer where it cannot be completed consistently with Bitkaya’s legal, compliance, or safeguarding obligations until resolved or escalated. | Hold, restriction and escalation records |
| 7 | Record the decision, authorization, reference, and execution result | All decisions, authorizations, holds, restrictions, and exceptions must be documented. | Decision, authorization, hold, restriction and exception records |
| 8 | Place and document a hold where required | Communicate only what is legally permitted, consistent with anti-tipping-off, confidentiality, or regulatory restrictions. | Hold documentation with confidentiality review |
| 9 | Escalate rejected, delayed, restricted, unusual or failed movements | Preserve the full audit trail for all escalated movements. | Escalation and audit trail records |
Records
- Client instruction, identity and authentication records
- Transaction recording with date, client identifier, amount and reference number
- Destination and wallet verification
- Screening, sanctions, wallet-exposure and risk review
- Maker-checker or dual-authorization records
- Hold, restriction, escalation, documentation and execution records
Relationships
- Policy: POL-SAFU-001 Client Asset Protection and Safeguarding Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-SAFU-003 Ensure Client Asset Movements Are Authorized and Permitted
History
- 2026-07-26: Created from sections 4-5, 12 and 14 of the approved SAFU Manual.