Purpose
Capture FATF expectations for suspicious transaction reporting and confidentiality of reporting activity.
Normative
Bitkaya shall identify, escalate, review and report suspicious virtual asset activity where required, and shall protect suspicious activity processes from tipping off, unauthorized disclosure or inappropriate client notification.
Descriptive
Local reporting to FIU Curaçao is made under applicable Curaçao rules. This FATF requirement supports the internal framework for escalation, review, decision-making, reporting, confidentiality and recordkeeping.
Source reference: SRC-FATF-001 FATF Virtual Assets and VASP Standards.
Assurance Assertions
- Suspicious activity escalation paths are documented.
- Reporting decisions and rationale are retained.
- Staff are trained not to tip off customers or counterparties.
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.