Objective
Ensure market-conduct responsibilities, permissions, risk assessments and proportionality decisions remain approved, current and traceable, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 sections 1, 2, 3.5, 9.1, 9.4, 11 and 12.
Control Activity
Compliance maintains the licensing matrix and market-conduct risk assessment and coordinates annual management and Board review of permissions, governance, proportionality, resources and material changes. The Compliance team maintains the jurisdictional licensing matrix to identify and track applicable requirements across regions; all licenses must be renewed timely and required filings submitted accurately and within statutory deadlines; services offered in each jurisdiction must align strictly with the permissions granted by regulators; employees and contractors are prohibited from conducting regulated activities in jurisdictions where Bitkaya lacks authorization (MCT 9.1). The Board retains ultimate responsibility for ensuring conduct and trading oversight remain effective; the Compliance Officer monitors adherence to the Market Conduct Manual and calibrates procedures in line with company size and regulatory expectations; Trading and Operations apply conduct rules daily ensuring fair order handling, client-first execution and transparency (MCT 12.3). Proportionality decisions are documented in internal compliance memoranda and version-controlled policy updates, supported by evidence of rationale (risk assessments, resource constraints, operational complexity) and reviewed annually by the Compliance Officer to confirm alignment with CBCS expectations and evolving market conditions; all proportionality-based adjustments are subject to internal audit or external review ensuring traceability and regulatory readiness (MCT 12.5).
Evidence
- Expected evidence: Jurisdictional licensing matrix and renewal evidence
- Expected evidence: Market-conduct risk assessment
- Expected evidence: Proportionality and automation decision (documented in internal compliance memoranda and version-controlled policy updates, supported by evidence of rationale)
- Expected evidence: Responsibility and separation-of-duties record
- Expected evidence: Management and Board approval of proportionality decisions (annual, documented in compliance reports)
- Expected evidence: Annual Compliance Officer review confirming alignment with CBCS expectations and evolving market conditions
- Evidence location: source evidence in SYS-ECM-001 Compliance Framework Library, 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 annual review and sample services and jurisdictions against permissions, risk and documented proportionality; verify services offered in each jurisdiction align strictly with regulator-granted permissions; confirm no regulated activity proceeds where authorization is absent or uncertain (MCT 3.5, 9.1).
- Testing frequency: annual and after material change
Relationships
- Requirements: REQ-VASP-002 Maintain CBCS Licensing Registration and Permissions, REQ-VASP-003 Maintain Governance and Fit and Proper Oversight
- Policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-MCT-001 Govern Market Conduct Permissions Risk and Proportionality
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 MCT Manual version 1.1.