Purpose
Ensure Bitkaya remains correctly classified and registered as a reporting service provider under the MOT framework.
Normative
Bitkaya shall maintain a documented assessment of its VASP activities against the MOT service perimeter, remain registered with FIU Curaçao in the prescribed digital reporting system, keep registration information current and retain evidence of registration and any required updates.
Descriptive
The 2024 amendment added VASPs to MOT Article 1(1)(a)(29). Article 132 of the 2025 VASP Ordinance subsequently aligned that provision with the statutory VASP definition.
Source references: MOT Articles 1, 15a and 15b; P.B. 2024, no. 41, Article II(A), (L) and (M); VASP Ordinance Article 132.
Assurance Assertions
- The legal-perimeter assessment identifies all Bitkaya VASP services.
- FIU registration is active and accessible to authorized personnel.
- Registration details and supporting evidence are reviewed after material changes.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Policy: POL-AML-001 AML CTF CPF Compliance Manual
- Procedure: PROC-AML-010 Review AML Policy and Proportionality Implementation
- Control: CTRL-AML-010 Ensure AML Policy Review and Proportionality Are Maintained
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from MOT Articles 1, 15a and 15b and the 2024 and 2025 VASP amendments.