BCMS

Ensure Market Abuse and Personal Trading Controls Operate

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Objective

Ensure manipulation, insider trading, front running, misuse of information and unmanaged personal conflicts are prevented and detected, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 sections 3, 4.3, 4.4 and 11.2.

Control Activity

Compliance maintains MNPI and restricted-asset controls, pre-approves all employee digital-asset trades, records conflicts and periodically reviews personal trading and market activity for restricted assets, suspicious timing, client-order proximity and misuse indicators. Bitkaya strictly prohibits any behavior intended to create false or misleading appearances of market activity, including wash trading, spoofing, layering, pump-and-dump schemes or disseminating rumors to distort asset prices; such practices undermine market integrity, erode client trust and may constitute criminal offenses under financial market regulations; employees must report any suspected manipulative activity to the Compliance team for investigation (MCT 3.1). The use of material non-public information (MNPI) for trading or advisory purposes is forbidden; employees must not buy, sell or recommend virtual assets where they possess MNPI such as details of pending listings, partnerships or regulatory approvals; confidential client or company data must never be exploited for personal benefit or to benefit third parties; employees handling sensitive information must adhere to information barrier (“Chinese Wall”) protocols to prevent inadvertent leaks (MCT 3.2). Bitkaya enforces zero-tolerance against front running; employees, officers or affiliates must not use advance knowledge of client orders to execute trades in their own accounts or on behalf of others before the client order is executed; front running is a serious breach of trust and may result in termination, regulatory reporting and potential criminal liability; surveillance systems are in place to detect patterns of activity that may suggest front running or related misconduct (MCT 4.3). All employees must obtain prior approval from the Compliance team before initiating trades in digital assets; employees may be restricted from trading in assets under consideration for listing, partnership or other strategic activity; personal trades are subject to periodic review to ensure compliance with disclosure and conflict of interest requirements; employees are strictly prohibited from using confidential client data, company strategy or other MNPI for personal trading; employees must not use knowledge of sanctions alerts, internal compliance escalations, onboarding restrictions, unusual activity reviews, pending approvals or other non-public control information for personal benefit or to benefit another person (MCT 4.4). Employees and management must promptly disclose any personal or financial interests that may conflict with Bitkaya’s business activities; acceptance of gifts, entertainment or favors that could improperly influence decision-making is prohibited; all partnerships, vendor arrangements and service agreements must be reviewed for potential conflicts with mitigation steps documented; where conflicts cannot be avoided, Bitkaya will adopt measures to manage, disclose and resolve them in a manner that prioritizes client interests (MCT 11.2).

Evidence

  • Expected evidence: MNPI and restricted-asset records (including information barrier / “Chinese Wall” protocols)
  • Expected evidence: Personal-trading request and decision (pre-approval from Compliance before initiating trades)
  • Expected evidence: Conflict disclosure and treatment (personal or financial interests, gifts, hospitality, third-party relationships)
  • Expected evidence: Periodic personal-trading review (restricted assets, suspicious timing, client-order proximity, misuse indicators)
  • Expected evidence: Market-abuse alert and investigation (including suspected manipulation, insider trading, front running)
  • Expected evidence: Surveillance system evidence for front running detection patterns
  • 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 employee trades and alerts for prior approval, information restrictions, timing, conflict review and escalation; verify no use of MNPI, client data, advance order knowledge or non-public sanctions and compliance information; confirm information barrier protocols are applied; confirm front running surveillance is operating.
  • Testing frequency: per request and periodic risk-based review

Relationships

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.

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