Objective
Ensure personnel complete role-appropriate mandatory training on time and demonstrate required competence.
Control Activity
Compliance maintains a role-based training matrix covering the four mandatory subjects — Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT), Anti-Bribery & Corruption (ABC), Cybersecurity Awareness, and Code of Ethics — assigns onboarding and annual training, monitors completion and assessment results, and escalates overdue or unsuccessful items for remediation. Training ensures personnel recognize risks such as fraud, insider trading, or cyber threats. All employees must complete training on time and refresh it annually or as required. Training content and frequency should be proportional to each employee’s responsibilities and risk exposure, and updated as the company grows.
Evidence
- Expected evidence: Approved training matrix and content
- Expected evidence: Assignment, attendance and completion records
- Expected evidence: Assessment and retraining results
- Expected evidence: Overdue and escalation reports
- 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: reconcile a sample of personnel and roles to required assignments, timely completion and satisfactory assessment
- Testing frequency: quarterly
Relationships
- Requirements: REQ-VASP-003 Maintain Governance and Fit and Proper Oversight, REQ-VASP-006 Maintain Controlled Operations and Security Controls
- Policy: POL-EMP-001 Employee Handbook
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Procedure: PROC-EMP-002 Assign Complete and Refresh Employee Training
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 Employee Handbook version 1.0.