Enterprise Compliance Manual

Purpose

Represent the approved Bitkaya Enterprise Compliance Manual as a BCMS publication and link the approved PDF artifact to the parent policy and governance process.

Audience

This publication is intended for Bitkaya directors, officers, employees, contractors, consultants, relevant third parties, auditors and authorized regulatory reviewers.

Source Objects

• Policy: POL-ECM-001 Enterprise Compliance Manual
• Process: PRC-OTC-001 High-Level Overview of Principal OTC Service Delivery
• Primary source: SRC-VASP-001 Landsverordening toezicht virtuele activa dienstverleners

Publication Rules

• Format: PDF
• Content cutoff: 21 April 2026
• Classification: confidential
• Retention: retain approved publication and superseded versions according to BCMS document-retention rules and applicable regulatory recordkeeping obligations

Approval

• Document title: Bitkaya Compliance Manual
• Version: 2.3
• Source status: FINAL
• Source date: 21 April 2026
• Approver shown in source: Board, based on the manual change log
• Exact Board approval date: 2026-04-21

Published Artifact

The approved PDF is stored in BCMS at:

Bitkaya Enterprise Compliance Manual v23 Approved.pdf

Coverage

This publication covers Bitkaya’s enterprise compliance framework, including compliance governance, risk management, outsourcing, AML/CFT/CPF, anti-bribery and corruption, KYC/CDD, client asset safeguarding, data protection, business continuity, market conduct, complaints handling, IT and cybersecurity, COTS acceptance, finance and tax compliance, employee conduct, internal controls and audit, regulatory reporting and training.

Relationships

• Parent policy: POL-ECM-001 Enterprise Compliance Manual
• Governance process: PRC-OTC-001 High-Level Overview of Principal OTC Service Delivery
• Parent procedures: PROC-ECM-001 Maintain Compliance Framework Inventory, PROC-ECM-002 Assess Regulatory Change and Framework Impact, PROC-ECM-003 Review Approve and Publish Compliance Manuals, PROC-ECM-004 Manage Compliance Reporting and Escalation, PROC-ECM-005 Manage Compliance Training and Attestations, PROC-ECM-006 Perform Compliance Assurance and Remediation
• Parent controls: CTRL-ECM-001 Ensure Compliance Framework Inventory Is Current, CTRL-ECM-002 Ensure Regulatory Change Impact Assessment Is Completed, CTRL-ECM-003 Ensure Compliance Manuals Are Approved and Version Controlled, CTRL-ECM-004 Ensure Compliance Reporting and Escalation Occurs, CTRL-ECM-005 Ensure Compliance Training and Attestations Are Completed, CTRL-ECM-006 Ensure Assurance Findings Are Tracked to Closure
• Parent systems: SYS-ECM-001 Compliance Framework Library, SYS-ECM-002 Compliance Reporting and Evidence Repository
• Related outsourcing manual publication: PUB-OUT-001 Outsourcing Risk Management Manual

Assurance

• PDF text extracted: yes
• Manual version captured: yes
• Manual date captured: yes, 2026-04-21
• Board approver captured from change log: yes
• Permanent artifact location captured: yes

History

• 2026-07-25: Created publication object from the supplied Bitkaya Enterprise Compliance Manual version 2.3 PDF.
• 2026-07-25: Updated publication status to implemented with Board approval and effective date 2026-04-21.
• 2026-07-25: Linked publication to the parent enterprise procedures, controls and systems.