Objective
Ensure authorized reviews, audits and regulatory inquiries receive complete, accurate, timely and traceable employee cooperation.
Control Activity
Compliance assigns response ownership, preserves evidence, reviews completeness and accuracy, authorizes external submissions and tracks requests, findings and remediation to closure. Verification requirements include:
- Employees must cooperate fully, providing accurate and complete information when requested.
- Attempts to withhold, alter, or falsify information must be identified and treated as serious misconduct.
- Reviews help the company stay compliant, improve processes, and strengthen trust — this rationale should be communicated to personnel.
- External regulatory communications must be routed through Compliance and authorized management.
- Leadership must ensure Bitkaya consistently meets all regulatory requirements, international standards, and ethical obligations, with compliance embedded in day-to-day operations.
Evidence
- Expected evidence: Request, scope, ownership and due-date record
- Expected evidence: Evidence-preservation and collection records
- Expected evidence: Accuracy review and submission approval
- Expected evidence: Correspondence, interviews and responses
- Expected evidence: Findings and remediation closure
- 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 review, audit and regulatory requests for timely assignment, complete response, approval and closed follow-up
- Testing frequency: semiannual and after each material regulatory request
Relationships
- Requirements: REQ-VASP-008 Retain Transaction Records and Regulatory Data, REQ-VASP-014 Cooperate With CBCS Supervision and Enforcement
- Policy: POL-EMP-001 Employee Handbook
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Procedure: PROC-EMP-006 Support Reviews Audits and Regulatory Cooperation
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.