Purpose
Register the practical AML and sanctions training for personnel handling client intake, onboarding support, relationship activity and first-line escalation.
Audience
Front Office, Operations, client-facing personnel and any person whose role captures client facts or can progress onboarding, access or transactions.
Source Objects
- POL-TRAIN-001 Training and Awareness Manual
- PUB-OTC-001 Bitkaya Principal OTC Service Flows Memo
- POL-AML-001 AML CTF CPF Compliance Manual
- POL-KYC-001 KYC and CDD Manual
- Linked MOT, LID, VASP and FATF requirements
Publication Rules
- Deliver before unsupervised client-facing or onboarding work and refresh at the matrix frequency.
- Assess sanctions stop rules, incomplete KYC, source-of-funds or source-of-wealth gaps, red flags, internal escalation and recordkeeping.
- Do not present internal escalation as external FIU reporting authority.
- Update when sanctions logic, KYC requirements, risk scoring, monitoring, wallet tooling or escalation routes change materially.
Approval
- Approval shown in artifact: none
- Required content owners: Compliance and Operations
- Required approver: Managing Director
- BCMS status remains
reviewuntil approval is evidenced.
Published Artifact
- Artifact: Bitkaya Front Office - AML & Sanctions Training PPT.pdf
- Pages: 12
- Document metadata creation date: 2026-05-02
- Artifact SHA-256:
eca0af3dd35f2dc0d4d814be589f15da903a5a740d62c9ec85c358374fa17cd9
Relationships
- Delivery procedure: PROC-TRAIN-003 Deliver Recurring and Role Specific Training
- AML training procedure: PROC-AML-008 Deliver AML Training and Awareness
- Evidence repository: SYS-ECM-002 Compliance Reporting and Evidence Repository
History
- 2026-07-26: Registered the supplied Front Office AML and Sanctions deck as a controlled training publication.