Objective
Ensure client orders are handled fairly, promptly, confidentially and under documented execution and compliance controls, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 section 4 and section 11.1.
Control Activity
Trading and Operations record order handling and execution factors and apply documented holds, restrictions or escalations where risk remains unresolved. Compliance reviews risk-based trade samples and execution quality regularly. In determining best execution, the firm considers price, speed, likelihood of execution and settlement, order size and prevailing market conditions; orders may be routed through different trading venues, exchanges or liquidity providers, but only where this aligns with the client’s best interests; clients will be informed of execution policies and any material limitations ensuring transparency in how their trades are handled; execution quality will be reviewed regularly and adjustments made to maintain high standards of client protection (MCT 4.1). Client orders must be managed with integrity, efficiency, confidentiality and appropriate control discipline; all orders must be handled in a fair and timely manner, but Bitkaya is not required to proceed with execution, settlement, transfer or release where legal, compliance, sanctions, fraud, safeguarding or operational concerns remain unresolved; where an order, payment flow, wallet destination, transaction pattern or client instruction presents unusual, inconsistent, restricted or higher-risk characteristics, the matter must be reviewed and, where necessary, escalated before further action is taken; order handling records must be sufficient to demonstrate the timing of the order, the actions taken, the persons involved, any restrictions or delays applied and the reason for any escalation, hold or refusal (MCT 4.2). Trading activity must be consistent with Bitkaya’s AML/CTF/CPF, sanctions, safeguarding and client protection obligations, including review of elevated-risk trading patterns, suspicious off-ramping and on-ramping behaviour, unusual transaction activity, sanctions or wallet exposure concerns and any other circumstances requiring escalation before execution, settlement or release of assets (MCT 4 intro). High-risk clients and transactions are subject to stronger review and escalation thresholds; suspicious activity identified through trading or settlement behaviour is escalated appropriately; legal or sanctions restrictions are respected before execution or release; control decisions are documented; and management information captures emerging risks, recurring issues and remediation actions (MCT 11.1).
Evidence
- Expected evidence: Order and handling audit trail (timing, actions, persons, restrictions, delays, escalation/hold/refusal reasons)
- Expected evidence: Execution-factor and venue decision (price, speed, execution/settlement likelihood, order size, market conditions, venue/liquidity-provider alignment with client interests)
- Expected evidence: Hold, restriction, escalation or refusal rationale (where legal, compliance, sanctions, fraud, safeguarding or operational concerns remain unresolved)
- Expected evidence: Settlement and release evidence
- Expected evidence: Client execution disclosure (execution policies and material limitations)
- Expected evidence: Execution-quality review and remediation (regular review with adjustments to maintain client protection)
- Expected evidence: Documented control decisions and management information on emerging risks, recurring issues and remediation actions
- 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 orders from receipt through execution, hold or refusal and confirm fair sequence, factors, records and escalation; verify records are sufficient to demonstrate timing, actions, persons, restrictions, delays and escalation/hold/refusal reasons; confirm high-risk clients and transactions are subject to stronger review and legal/sanctions restrictions are respected before execution or release.
- Testing frequency: per order with regular risk-based sample review
Relationships
- Requirements: REQ-VASP-005 Maintain Integrity Based Business Operations, REQ-VASP-013 Control Specific Virtual Asset Services
- Policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-MCT-003 Manage Best Execution and Client Order Handling
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.