Purpose
Translate the VASP Ordinance into a testable BCMS requirement for licensing, registration, exemptions, dispensations and CBCS permissions.
Normative
Bitkaya shall not conduct regulated VASP activities in or from Curacao unless the required CBCS licence, exemption, dispensation, registration or permission has been obtained and remains valid.
Descriptive
The licensing process should identify required application information, maintain evidence submitted to CBCS, track conditions or limitations attached to any licence or permission, and prevent launch or continuation of regulated activities outside the approved scope. Article 15(1)(c)-(d) is excluded from commencement and should not be treated as effective unless later brought into force.
Source reference: VASP Ordinance, Articles 7 through 19 and 134; commencement instrument Publicatieblad A 2025 No. 91, Article 1.
Assurance Assertions
- A licence, exemption, dispensation or registration status record exists.
- Regulated VASP services are not launched outside the approved CBCS scope.
- Conditions, limitations, changes, expiry or withdrawal risks are tracked.
Relationships
- Source: SRC-VASP-001 Landsverordening toezicht virtuele activa dienstverleners
- Policies: POL-AML-001 AML CTF CPF Compliance Manual, POL-ECM-001 Enterprise Compliance Manual
- Processes: PRC-FCI-001 Financial Crime and Integrity, PRC-OTC-001 High-Level Overview of Principal OTC Service Delivery
- Procedures: PROC-AML-002 Perform Client Acceptance CDD EDD and Risk Classification, PROC-AML-006 Apply Travel Rule and Counterparty VASP Due Diligence, PROC-AML-010 Review AML Policy and Proportionality Implementation
- Controls: CTRL-MCT-001 Ensure Market Conduct Governance Permissions and Risk Are Current, CTRL-RMF-005 Ensure New Products and Material Changes Are Approved, CTRL-REG-001 Ensure Regulatory Obligations and Calendar Are Current, CTRL-REG-004 Ensure CBCS Reporting and Notifications Are Controlled
- Systems: not yet assigned; tracked under ISS-VASP-001
- Issues: ISS-VASP-001
- Publications: pending
Assurance
- Source verified: yes
- Implementation linked: partial; mapped to current BCMS implementation objects while detailed VASP coverage remains planned
- Wording unambiguous: review
History
- 2026-07-25: Created from SRC-VASP-001, including embedded commencement details.
- 2026-07-26: Added policy, process and procedure mappings; detailed VASP implementation remains planned.