Objective
Ensure published and operational communications are monitored and material deficiencies are corrected, escalated and remediated.
Control Activity
At least quarterly, Compliance tests a documented risk-based sample across active channels. Findings are assessed for client, legal, conduct, privacy, sanctions and reporting impact. Material content is removed or corrected promptly, serious or recurring matters are escalated, and corrective action is tracked to verified closure.
Verification Requirements (Section 8 and Section 9 of the Approved Manual)
Verify that monitoring covers published and operational communication to identify:
- misleading language;
- inconsistent statements;
- inappropriate promises;
- weak disclosures; or
- communications that could conflict with legal, sanctions, or compliance obligations.
Proportional Monitoring Verification (Section 11.3)
Verify that communication monitoring is performed quarterly, rather than daily, reflecting the current scale of marketing activity. Confirm that proportional sample testing of advertisements, website updates, and client communications is used to confirm ongoing compliance. Verify that the Compliance Officer reports findings to management, and that the frequency or scope of monitoring may increase as the business scales.
Breach Escalation Verification (Section 9)
Verify that misleading, incomplete, or inappropriate communication has been assessed for legal, regulatory, client protection, and reputational risk. Where a communication issue touches on sanctions, unusual activity review, legal restrictions, or internal compliance handling, verify the matter was escalated and assessed in coordination with the relevant control functions. Verify that any staff communication inappropriately disclosing, confirming, or implying the existence of a sanctions review, unusual activity assessment, or internal reporting process has been treated as a serious control breach.
Evidence
- Expected evidence: Monitoring population, sample and test record
- Expected evidence: Finding and impact assessment
- Expected evidence: Original, corrected and withdrawn content
- Expected evidence: Escalation and reporting decision
- Expected evidence: Corrective-action and effectiveness evidence
- 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 each quarterly cycle and trace material findings through correction, escalation and closure
- Testing frequency: quarterly and after identified incidents
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMM-006 Monitor Communications Investigate Breaches and Correct Content
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.