Purpose
Ensure transaction monitoring consistently applies the legally prescribed VASP indicators.
Normative
Bitkaya shall maintain and apply the current objective and subjective VASP indicators prescribed under MOT Article 10, including any legally effective replacement amounts, currency references or amended indicator definitions.
Descriptive
P.B. 2024, no. 60, Article 14b and Annex O currently identify these VASP indicators:
- a transaction reported to police or justice;
- a transaction contrary to applicable sanctions rules;
- a cash transaction of NAf 20,000 or more, including an exchange between virtual assets and cash fiduciary currency;
- a transaction of NAf 30,000 or more; and
- a transaction giving reason to suppose a connection with money laundering, terrorist financing or proliferation financing.
Thresholds and currency references must be checked against later subordinate legislation before operational use.
Source references: MOT Article 10; P.B. 2024, no. 60, Article 14b and Annex O.
Assurance Assertions
- The monitoring rule inventory maps every current VASP indicator to a control or review step.
- Objective thresholds are configuration-controlled and independently checked.
- The subjective indicator supports documented human escalation based on suspicion.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Procedure: PROC-AML-004 Perform Transaction Monitoring and Alert Review
- Control: CTRL-AML-004 Ensure Transaction Monitoring Alerts Are Reviewed
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from MOT Article 10 and the VASP indicators in P.B. 2024, no. 60.