Purpose
Prevent service activation or continuation when legally required CDD is incomplete.
Normative
Bitkaya shall complete the required identification, verification and ownership checks before onboarding or executing an applicable occasional transaction, shall not provide service where CDD cannot achieve the required result, and shall terminate an existing relationship when statutory CDD cannot be completed.
Descriptive
Any delayed verification exception may be used only where legally available, low risk, necessary to avoid disruption and completed as soon as possible with use restrictions where required.
Source reference: LID Articles 2a and 2b.
Assurance Assertions
- Activation is blocked until mandatory CDD is complete.
- Delayed-verification exceptions are documented and controlled.
- Incomplete existing relationships are terminated and escalated.
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 Articles 2a and 2b.