Objective
Ensure relevant staff remain competent and communication controls scale with activity and risk.
Control Activity
Compliance identifies relevant roles, provides onboarding and role-based training, assesses completion and understanding, and remediates failures. At least annually, management reviews products, clients, channels, jurisdictions, monitoring results, complaints and incidents to determine whether approval, monitoring, systems, staffing and reporting controls remain proportionate.
Verification Requirements (Section 8 of the Approved Manual)
Verify that training ensures staff understand:
- what they may and may not say about onboarding, restrictions, escalation, and internal reviews;
- how to communicate delays or restrictions appropriately;
- the importance of avoiding anti-tipping-off breaches;
- when standard wording must be used; and
- when Compliance approval is required before sending or publishing content.
Proportionality in Training Verification (Section 11.3)
Verify that targeted compliance training focuses on staff directly engaged in client communication, marketing, and onboarding. Confirm that frequency and depth of training are proportionate to the risk exposure of each function: new employees receive foundational training, while marketing and client service staff receive more detailed sessions.
Scalability Review Verification (Section 11.4)
Verify that periodic proportionality reviews ensure controls remain aligned with regulatory expectations and organizational capacity. For a small VASP such as Bitkaya, confirm:
- Communication approval may rest with a single Compliance Officer and one member of management.
- Monitoring and reporting cycles may be less frequent but must remain evidence-based and documented.
- Use of pre-approved templates, disclaimers, and concise communication reduces operational burden while ensuring compliance with Articles 42, 45, and 46 of the LvT VAD.
- As operations scale, the system must adapt to include automated review tools, more frequent audits, and layered management oversight.
Verify that the framework can evolve from basic controls to more sophisticated review, automation, and reporting systems as Bitkaya expands its services, client base, or jurisdictions.
Evidence
- Expected evidence: Training needs and role mapping
- Expected evidence: Training materials, attendance and assessment
- Expected evidence: Remedial and refresher training
- Expected evidence: Annual proportionality review
- Expected evidence: Management decisions and completed improvements
- 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 training coverage and the annual review and trace identified changes to accountable action and completion
- Testing frequency: on onboarding, periodically by role, and annual proportionality review
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMM-007 Train Staff Review Proportionality and Scale 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
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMM Manual.