Purpose
Control reliance on third parties and the use of statutory exemptions or simplified treatment.
Normative
Bitkaya shall rely on an intermediary or third party only after confirming equivalent legal duties, effective supervision, immediate information access and possession of identity documentation, and shall apply simplified treatment or exemptions only where the statutory conditions are evidenced.
Descriptive
Article 131 of the VASP Ordinance amends Article 2e for registered VASPs. This does not remove the need to collect enough information to prove eligibility or to apply enhanced measures required elsewhere.
Source reference: LID Articles 2c and 2e; VASP Ordinance Article 131.
Assurance Assertions
- Third-party reliance assessments are documented.
- Identity evidence remains available to Bitkaya.
- Every simplified-treatment decision records its legal basis and eligibility evidence.
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 2c and 2e and VASP Ordinance Article 131.