Purpose
Translate the VASP Ordinance into a testable BCMS requirement for client-facing information, advertising, tariff disclosure and public disclosures.
Normative
Bitkaya shall ensure that VASP information, advertising, tariff disclosures, client communications and public disclosures are factual, clear, not misleading and aligned with client protection obligations.
Descriptive
The disclosure framework should cover advertising, service information, tariff policy, public website disclosures, conflict-of-interest disclosures, white paper-related disclosures where applicable, and periodic public information required by CBCS regulations.
Source reference: VASP Ordinance, Articles 42 and 46; commencement instrument Publicatieblad A 2025 No. 91, Article 1.
Assurance Assertions
- Client and public information is reviewed before publication.
- Tariff policy is publicly available where required.
- Conflicts, white paper information and periodic public disclosures are managed where applicable.
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
- Procedure: PROC-ECM-003 Review Approve and Publish Compliance Manuals
- Controls: CTRL-MCT-004 Ensure Market Communications Are Accurate and Approved, CTRL-MCT-006 Ensure Market Conduct Complaints Are Handled Fairly, CTRL-RMF-005 Ensure New Products and Material Changes Are Approved, CTRL-ESG-004 Ensure Community and Partnership Activities Are Responsible, CTRL-ESG-006 Ensure ESG Risk Is Integrated Into Material Decisions, CTRL-ESG-007 Ensure ESG Reporting Proportionality and Improvement Are Current, CTRL-PRIV-002 Ensure Data Subject Requests and Privacy Information Are Controlled, CTRL-COMP-001 Ensure Complaints Governance Channels and Information Are Current, CTRL-COMP-005 Ensure Complaints Are Resolved Remediated and Answered on Time, CTRL-COMM-001 Ensure Communication Standards and Approved Wording Are Current, CTRL-COMM-002 Ensure Channel Communications Are Accurate Clear and Balanced, CTRL-COMM-003 Ensure Material Risks and Service Limitations Are Prominent, CTRL-COMM-004 Ensure Onboarding and Restricted Matter Communications Are Safe, CTRL-COMM-005 Ensure External Communications Are Approved Versioned and Retained, CTRL-COMM-006 Ensure Communications Are Monitored and Breaches Corrected, CTRL-COMM-007 Ensure Communication Training and Proportionality Review Occur, CTRL-SAFU-004 Ensure Client Assets Are Reconciled and Reported Accurately, CTRL-SAFU-007 Ensure Safeguarding Terms and Client Communications Are Accurate
- Systems: not yet assigned; tracked under ISS-COMP-001, ISS-COMM-001, ISS-SAFU-001, ISS-OTC-001
- Issues: ISS-COMP-001 Confirm Complaints Channels Register and CBCS Source, ISS-COMM-001 Confirm Licensing Claims Approval Workflow and Operating Evidence, ISS-SAFU-001 Confirm Safeguarding Architecture Legal Protections and Operating Evidence, ISS-OTC-001 Review and Complete Principal OTC Service Flow Controls
- Publications: PUB-OTC-001 Bitkaya Principal OTC Service Flows Memo
Assurance
- Source verified: yes
- Implementation linked: yes; the dedicated COMM policy, process, procedures and controls are mapped
- 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 disclosure implementation remains planned.
- 2026-07-26: Added the dedicated COMM framework and replaced the detailed disclosure implementation gap.