Purpose
Capture the FATF expectation that VASPs are licensed or registered and subject to effective supervision or monitoring.
Normative
Bitkaya shall maintain evidence that it is operating within the applicable VASP licensing, registration, permission or transitional regime and shall remain ready for supervisory review by competent authorities.
Descriptive
This requirement supports FATF Recommendation 15 expectations on licensing or registration and supervision. For Bitkaya, local legal effect is governed by Curaçao law and CBCS implementation, while FATF remains the international standard baseline.
Source reference: SRC-FATF-001 FATF Virtual Assets and VASP Standards.
Assurance Assertions
- Licensing or registration status is recorded and monitored.
- Material changes that may affect supervisory status are escalated.
- Supervisory requests can be supported with current compliance evidence.
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.