Purpose
Translate the VASP Ordinance into a testable BCMS requirement for own funds, solvency and safeguarding of client fiat currency, virtual assets and access means.
Normative
Bitkaya shall maintain required own funds, solvency and safeguarding arrangements for client fiat currency, virtual assets and access means used in regulated VASP activities.
Descriptive
Safeguarding arrangements should cover minimum own funds, solvency, segregation or protection of fiat currency, safeguarding through eligible accounts or guarantees where applicable, separate payment accounts, safeguarding of virtual assets and access means, and prompt CBCS notification when Bitkaya foresees that financial safeguard requirements are no longer or will no longer be met.
Source reference: VASP Ordinance, Articles 28 through 34; commencement instrument Publicatieblad A 2025 No. 91, Article 1.
Assurance Assertions
- Own funds and solvency requirements are monitored.
- Client fiat currency, virtual assets and access means are safeguarded according to applicable rules.
- Potential breach of financial safeguard requirements is escalated and notified where required.
Relationships
- Source: SRC-VASP-001 Landsverordening toezicht virtuele activa dienstverleners
- Policy: POL-ECM-001 Enterprise Compliance Manual
- Process: PRC-OTC-001 High-Level Overview of Principal OTC Service Delivery
- Procedures: PROC-ECM-004 Manage Compliance Reporting and Escalation, PROC-ECM-006 Perform Compliance Assurance and Remediation
- Controls: CTRL-MCT-005 Ensure Client Assets and Custody Are Safeguarded, CTRL-SAFU-001 Ensure Safeguarding Governance Training and Proportionality Are Maintained, CTRL-SAFU-002 Ensure Client Assets Are Segregated and Fully Matched, CTRL-SAFU-004 Ensure Client Assets Are Reconciled and Reported Accurately, CTRL-SAFU-005 Ensure Safeguarding Providers and Continuity Are Controlled, CTRL-SAFU-008 Ensure Safeguarding Breaches Resolution and Assurance Are Effective, CTRL-RMF-001 Ensure Risk Governance Appetite and Taxonomy Are Current, CTRL-RMF-004 Ensure Material Risk Scenarios Are Tested, CTRL-ICA-002 Ensure Core Internal Control Coverage Is Complete, CTRL-ICA-005 Ensure External and Regulatory Audits Are Supported, CTRL-REG-004 Ensure CBCS Reporting and Notifications Are Controlled, CTRL-REG-005 Ensure Tax and Audited Financial Reports Are Timely, CTRL-FIN-001 Ensure Finance Tax Governance Calendar and Proportionality Are Current, CTRL-FIN-002 Ensure Books Records and Financial Close Are Complete and Accurate, CTRL-FIN-003 Ensure Annual Financial Statements Are Approved Reviewed Submitted and Published, CTRL-FIN-006 Ensure Finance Movements Reconciliations and Exceptions Are Controlled
- Systems: SYS-FIN-001 Odoo Accounting ERP
- Issues: ISS-SAFU-001 Confirm Safeguarding Architecture Legal Protections and Operating Evidence, ISS-FIN-001 Confirm Finance and Tax Sources Thresholds Systems and Operating Evidence
- Publications: PUB-FIN-001 Bitkaya Accounting Treatment in Odoo SOP, PUB-TRAIN-004 Finance Department Compliance Training
Assurance
- Source verified: yes
- Implementation linked: partial; parent-framework escalation and assurance are mapped while detailed finance safeguards remain planned
- Wording unambiguous: review
History
- 2026-07-25: Created from SRC-VASP-001, including embedded commencement details.
- 2026-07-26: Added interim enterprise policy, process and procedure mappings; detailed finance implementation remains planned.