Purpose
Maintain the governance, competence and cooperation needed for effective MOT compliance.
Normative
Bitkaya shall maintain documented reporting governance, trained and authorized personnel, effective administrative organization and internal controls, and shall fully implement binding supervisory prescriptions and directions. Bitkaya shall provide requested information, records, system access and other legally required cooperation to the competent supervisor and FIU.
Descriptive
The supervisor may issue requirements concerning staff competence, training, administrative organization, internal control and report quality. Failure to comply with reporting, registration, information, suspension, confidentiality, direction or cooperation obligations can lead to administrative or criminal enforcement.
Source references: MOT Articles 15a, 15b, 20a, 22v, 22mm and 23.
Assurance Assertions
- Reporting roles, delegated authorities and backups are documented.
- Relevant personnel complete periodic MOT and FIU-reporting training.
- Supervisory requests and directions are logged, assigned and evidenced to closure.
- Independent review tests MOT reporting design and operation.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Procedure: PROC-AML-008 Deliver AML Training and Awareness
- Procedure: PROC-AML-009 Perform AML Independent Review and Remediation
- Procedure: PROC-AML-010 Review AML Policy and Proportionality Implementation
- Control: CTRL-AML-008 Ensure AML Training Is Completed
- Control: CTRL-AML-009 Ensure AML Independent Review Findings Are Tracked
- 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 registration, governance, direction, supervision and enforcement provisions.