Objective
Ensure website, white-paper, social-media, advertising, document and email content is accurate, understandable, substantiated and suitable for its channel and audience.
Control Activity
Content owners document audience, channel, jurisdiction and purpose and substantiate factual and comparative claims. Compliance verifies that wording, images, slogans, calls to action and disclaimers do not mislead, exaggerate, create artificial urgency or imply guaranteed outcomes.
Verification Requirements (Section 5 of the Approved Manual)
Channel-specific content must be verified against the following rules:
Website & Whitepapers: Verify factual accuracy, regular updates, and Compliance approval. Confirm that whitepapers (if Bitkaya issues tokens) have Central Bank approval (Art. 46).
Social Media: Verify that prohibited claims are absent — specifically “Guaranteed profits,” “Risk-free trading,” and “Limited time double-your-money.” Verify that allowed content (educational posts, service updates, factual comparisons with references) carries required disclaimers (e.g., “#CryptoRisks notguaranteed”).
Advertising: Verify that risks and benefits have the same prominence. Confirm no promises of fixed returns. Verify that images and slogans do not mislead (e.g., luxury cars suggesting wealth creation).
Client Documents & Emails: Verify that communications make clear that: (a) onboarding and transaction processing are subject to legal, compliance, and sanctions controls; (b) additional information or documentation may be required depending on the client’s risk profile or activity; (c) Bitkaya may delay, restrict, refuse, block, or report certain activity where required by law or internal control procedures; and (d) Bitkaya may be legally restricted in what it can disclose about certain reviews, escalations, or restrictions. Confirm that standard language touching onboarding, due diligence, restrictions, escalation, safeguarding, or legal reporting matters has been reviewed by Compliance.
Evidence
- Expected evidence: Content brief and audience assessment
- Expected evidence: Claims substantiation
- Expected evidence: Channel-specific review checklist
- Expected evidence: Draft, images and disclaimers
- 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 communications across channels and verify facts, substantiation, audience suitability and balanced presentation
- Testing frequency: before publication with quarterly sample testing
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMM-002 Draft Channel Specific Communications and Promotions
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.