Purpose
Establish the FATF-based requirement for sanctions and proliferation-financing risk controls in virtual asset activity.
Normative
Bitkaya shall maintain controls to identify, assess, screen, mitigate and escalate sanctions and proliferation-financing risks associated with customers, counterparties, wallets, transactions, jurisdictions and virtual asset typologies.
Descriptive
FATF standards and targeted updates highlight PF risk assessment, targeted financial sanctions and misuse of virtual assets by sanctioned actors. Controls should include customer and wallet screening, blockchain exposure review, escalation and asset-freezing or blocking workflows where legally required.
Source reference: SRC-FATF-001 FATF Virtual Assets and VASP Standards.
Assurance Assertions
- Sanctions and PF risk are included in VA/VASP risk assessment.
- Customers, wallets and relevant counterparties are screened according to risk.
- Potential sanctions or PF matches are escalated and handled under approved procedures.
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.