Purpose
Translate the LID’s core customer-due-diligence obligation into a testable BCMS requirement.
Normative
Bitkaya shall perform risk-based CDD that identifies and verifies the client and UBO, understands ownership and control, establishes purpose and intended nature, verifies representatives and third-party capacity, and continuously monitors the relationship and transactions against the client risk profile.
Descriptive
CDD is required when entering a relationship, for applicable occasional or linked transactions, when ML/TF suspicion exists, when prior data is doubtful and in other statutory trigger circumstances.
Source reference: LID Article 2.
Assurance Assertions
- Required client, UBO, purpose and representative data are collected and verified.
- CDD depth is proportionate to risk.
- Ongoing monitoring includes source-of-funds inquiry where needed.
Relationships
- Source: SRC-LID-001 Landsverordening identificatie bij dienstverlening
- Procedure: PROC-AML-002 Perform Client Acceptance CDD EDD and Risk Classification
- Control: CTRL-AML-002 Ensure CDD EDD and Client Acceptance Are Completed
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from LID Article 2.