Purpose
Define the FATF-driven requirement to determine whether Bitkaya activities, products, counterparties or services fall within virtual asset or VASP scope.
Normative
Bitkaya shall assess whether its activities, products, services, counterparties and planned changes fall within FATF virtual asset or VASP definitions and shall document the regulatory-perimeter conclusion.
Descriptive
The assessment should consider the FATF definitions of virtual asset and virtual asset service provider, including exchange, transfer, safekeeping or administration, participation in financial services related to issuance or sale, and activities performed for or on behalf of another person. Borderline services, new products and technology models should be escalated for Compliance review.
Source reference: SRC-FATF-001 FATF Virtual Assets and VASP Standards.
Assurance Assertions
- New or changed services receive documented VA/VASP scope assessment.
- Borderline or novel activities are escalated before launch.
- Scope conclusions are linked to applicable requirements and controls.
Relationships
- Source: SRC-FATF-001 FATF Virtual Assets and VASP Standards
- Parent policy: POL-ECM-001 Enterprise Compliance Manual
- Process: PRC-OTC-001 High-Level Overview of Principal OTC Service Delivery
- Regulatory-change procedure: PROC-ECM-002 Assess Regulatory Change and Framework Impact
- Regulatory-change control: CTRL-ECM-002 Ensure Regulatory Change Impact Assessment Is Completed
- Framework library: SYS-ECM-001 Compliance Framework Library
- Related VASP requirements: REQ-VASP-001 through REQ-VASP-015, where applicable
- Detailed AML/CFT/CPF manual objects: pending
Assurance
- Source verified: yes
- Implementation linked: parent-framework only
- Wording unambiguous: review
- Detailed operating procedure linked: pending future detailed manuals where applicable
History
- 2026-07-25: Created from consolidated FATF VA/VASP source object.