Objective
Ensure payments, invoices, commissions, expenses and related records are legitimate, supported, approved, accurate and auditable.
Control Activity
Finance verifies purpose, payee, invoice, service evidence, commercial rationale and approval before payment. Bitkaya prohibits any falsification, concealment, or mischaracterization of payments, invoices, commissions, reimbursements, contracts, approvals, or supporting documents. Minimum control standards include documented payment approval workflows, legitimate invoices and supporting evidence for payments, no off-book accounts or side arrangements, commercially justifiable commissions and consulting fees, accurate and reviewable expense claims, and escalation of unusual invoices, duplicate claims, round-sum charges, or vague service descriptions. Unusual invoices, duplicate claims, round-sum charges, vague service descriptions, unrelated payees, offshore payment requests and unsupported reimbursements are stopped and escalated to Compliance. Records must be retained for at least the period required by applicable law or internal policy, and longer where there is litigation, investigation, audit, or regulatory need.
Evidence
- Expected evidence: Invoice, contract and service evidence
- Expected evidence: Payment and expense approvals
- Expected evidence: Commission or consulting-fee rationale
- Expected evidence: Exception and escalation records
- Expected evidence: Corrective accounting and audit trail
- Evidence location: source evidence in SYS-ECM-002 Compliance Reporting and Evidence Repository; target Hermes assessment record in Odoo under ISS-HERMES-001.
- Retention: according to the applicable approved policy and Bitkaya record-retention requirements.
- Testing method: sample payments and exceptions for valid support, approval, payee, rationale, recording and escalation
- Testing frequency: per transaction with periodic risk-based sample testing
Relationships
- Requirements: REQ-VASP-005 Maintain Integrity Based Business Operations, REQ-VASP-008 Retain Transaction Records and Regulatory Data
- Policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Procedure: PROC-ABC-005 Apply ABC Books Records and Financial Controls
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.
- Design status: implemented
History
- 2026-07-28: Enriched control activity with the full falsification prohibition scope and minimum control standards list (section 13) and retention-period guidance (section 18).
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved ABC Manual version 1.0.