Objective
Ensure holdings agree with client entitlements and clients receive complete, accurate and timely monthly statements. Accurate reconciliation and record-keeping are essential to safeguarding client assets and supporting legal, regulatory, operational, and audit requirements.
Control Activity
Operations performs weekly reconciliation under the current early-stage model, comparing internal records with external bank and wallet statements to ensure reported balances accurately reflect the assets actually held on behalf of clients. Any inconsistencies are investigated immediately and resolved without delay, with corrective actions documented to ensure accountability and prevent recurrence. Material or overdue breaks are escalated and affected movement is restricted where protection requires it. Complete and auditable records are maintained of: client balances and entitlements; receipts, disbursements, and transfers; wallet addresses and payment instructions; authorization and approval records; holds, restrictions, reversals, and exceptions; reconciliation differences and their resolution; and any linked compliance or safeguarding escalations. Where a safeguarding event overlaps with a sanctions, fraud, AML/CTF/CPF, cybersecurity, or operational incident, records support cross-reference to the relevant escalation and remediation process. Records are retained for at least the minimum period mandated by applicable laws and regulations. Monthly statements showing client money balances, virtual asset holdings, period transactions, and any interest earned or charges applied are delivered within 25 calendar days of the statement date. Reports are clear, accurate, and free from omissions or misleading information. Client-reported discrepancies are corrected promptly.
Verification Requirements
- Verify that weekly reconciliations are performed comparing internal records with external bank and wallet statements, and that frequency increases with scale and risk.
- Verify that reconciliations cover asset, account or wallet, client entitlement, transaction and total holding.
- Verify that inconsistencies identified during reconciliation are investigated immediately and resolved without delay, with corrective actions documented.
- Verify that material or overdue differences are escalated and affected movement is restricted where protection requires it.
- Verify that complete and auditable records are maintained for client balances, entitlements, receipts, disbursements, transfers, wallet addresses, authorization records, holds, restrictions, reversals, exceptions, reconciliation differences, and linked compliance or safeguarding escalations.
- Verify that where a safeguarding event overlaps with a sanctions, fraud, AML/CTF/CPF, cybersecurity, or operational incident, records support cross-reference to the relevant escalation and remediation process.
- Verify that records are retained for at least the minimum period mandated by applicable laws and regulations, and longer where necessary.
- Verify that monthly statements show client money balances, virtual asset holdings, transactions conducted during the reporting period, and any interest earned or charges applied.
- Verify that statements are clear, accurate, and free from omissions or misleading information.
- Verify that statements are delivered within 25 calendar days of the statement date.
- Verify that client-reported discrepancies are promptly investigated and corrected.
Evidence
- Expected evidence: Weekly reconciliation and approval
- Expected evidence: Difference investigation and remediation
- Expected evidence: Monthly statement and delivery evidence
- Expected evidence: Client discrepancy correction
- 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: reperform sampled reconciliations and statement timeliness and trace differences to closure
- Testing frequency: weekly reconciliation and monthly reporting
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 SAFU Manual.