Purpose
Protect confidential reporting information and prevent unauthorized disclosure to clients or third parties.
Normative
Bitkaya shall restrict MOT reports, FIU requests, reporting decisions, suspension instructions and related information to authorized persons with a legitimate need to know, prohibit disclosure or use beyond the legally permitted purpose and prevent tipping off a client or other unauthorized person.
Descriptive
Good-faith reporting and information provision receive statutory criminal and civil protections, but those protections do not remove the confidentiality duties that apply to reporting information.
Source references: MOT Articles 14, 15 and 20.
Assurance Assertions
- FIU case information is subject to role-based access and confidentiality controls.
- Client communications do not reveal a report, inquiry or suspension instruction.
- Access and disclosures are logged and periodically reviewed.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Procedure: PROC-AML-005 Perform FIU Reporting and Case Escalation
- Procedure: PROC-AML-007 Maintain AML Records and Data Retention
- Control: CTRL-AML-005 Ensure FIU Reporting and Case Escalation Are Completed
- Control: CTRL-AML-007 Ensure AML Records Are Retained and Retrievable
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from MOT Articles 14, 15 and 20.