Objective
Ensure submissions are reconciled, independently reviewed, authorized and filed by deadline, in accordance with the Communication Framework standards for tone and format.
Control Activity
Each filing requires a completed checklist, source reconciliation, maker-checker review, approval and retained submission receipt. Compliance verifies that each submission adheres to the Communication Framework:
Tone verification: Submissions must present information objectively without speculation, avoid jargon, use clear and precise language, reflect transparency by disclosing all relevant facts (even if adverse) while highlighting corrective measures, and be delivered within regulatory deadlines.
Format verification: Submissions must use the correct format — formal letters signed by authorized representatives for official submissions, emails for routine updates, or regulatory portals for mandatory filings (FIU reports, tax submissions, CBCS templates). In-person or telephone conversations must be documented in writing immediately afterward.
Calendar verification: Each filing must be reconciled to the reporting calendar for the applicable authority, report type, frequency, and deadline (e.g., CBCS prudential/AML report due 30 days after quarter-end, CIT return due 5 months after year-end, turnover and wage tax due 15th of the following month).
Evidence
- Expected evidence: Filing checklist, source data and reconciliation
- Expected evidence: Review and approval
- Expected evidence: Final report and portal receipt
- 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 filings for completeness, accuracy, authorization, timeliness and follow-up
- Testing frequency: quarterly
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.