Objective
Ensure communication ownership, channel inventory, approved wording and regulatory representations are controlled and current.
Control Activity
Compliance maintains the communication governance matrix, channel inventory and approved-wording library. Standard statements record permitted use, source, approval and review dates. Licensing and supervision representations require current documented verification. Obsolete or conflicting wording is withdrawn and affected live content is updated.
Verification Requirements
The approved-wording library must be verified against Section 10 of the approved manual to confirm the following standard templates are included with exact wording:
- Risk Disclaimer for Ads: “Virtual assets are high-risk and volatile. You may lose your entire investment. Bitkaya is licensed under the Landsverordening toezicht virtuele activa dienstverleners and supervised by the Central Bank of Curaçao and Sint Maarten.”
- Website Footer: “Bitkaya N.V. is licensed and supervised by the Centrale Bank van Curaçao en Sint Maarten as a Virtual Asset Service Provider (VASP). Investments in virtual assets involve significant risks, including volatility, regulatory changes, and possible total loss of capital.”
- Email Signature Disclaimer: “This communication is for informational purposes only and does not constitute financial advice. Virtual assets are volatile and may result in a total loss of funds.”
The five Mandatory Risk Statements from Section 4 (Volatility, Loss of Capital, Regulatory Changes, Technology Risks, AML/CTF Monitoring) must each be present in the library with their exact approved wording.
Licensing representations must not be used automatically — Compliance must confirm current legal status before any communication states or implies Bitkaya is licensed, authorized, registered or supervised (per the Restricted Licensing Representations section and ISS-COMM-001).
Evidence
- Expected evidence: Roles and approval-authority matrix
- Expected evidence: Channel and communication inventory
- Expected evidence: Approved-wording library and change history
- Expected evidence: Regulatory-status verification
- Expected evidence: Annual and change-triggered review
- 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: inspect governance records and sample standard statements for source, approval, permitted use, currency and live-content alignment
- Testing frequency: annual and after material change
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMM-001 Govern Communication Standards and Approved Wording
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
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMM Manual.