Purpose
Consolidate the LID’s enhanced controls for elevated-risk clients, relationships, delivery channels and technologies.
Normative
Bitkaya shall apply documented enhanced measures for PEPs, applicable correspondent or analogous relationships, anonymity-enhancing technology, non-face-to-face business and persons or transactions connected to jurisdictions with strategic AML/CFT deficiencies.
Descriptive
Measures include senior-management approval, source-of-wealth and source-of-funds work, enhanced monitoring, additional identity evidence and authenticity checks, counterparty assessment and controls against prohibited shell-bank exposure where applicable.
Source reference: LID Articles 5a through 5e and 5i.
Assurance Assertions
- PEP and high-risk jurisdiction rules are implemented.
- Non-face-to-face and technology risks have compensating controls.
- Senior approval and enhanced monitoring evidence are retained where required.
Relationships
- Source: SRC-LID-001 Landsverordening identificatie bij dienstverlening
- Procedures: PROC-AML-001 Maintain AML Risk Assessment and SARA Calibration, PROC-AML-002 Perform Client Acceptance CDD EDD and Risk Classification, PROC-AML-006 Apply Travel Rule and Counterparty VASP Due Diligence
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from LID Articles 5a through 5e and 5i.