Purpose
Translate the VASP Ordinance into a testable BCMS requirement for ownership, control, appointment and material change notifications.
Normative
Bitkaya shall obtain required CBCS consent or provide required CBCS notice before executing qualifying holdings, control changes, appointments, statutory changes, structural changes or other material VASP business changes.
Descriptive
The change-control framework should cover qualified holdings, voting control, share transfers, threshold changes, January annual qualified-holding reporting, management and supervisory appointments, antecedent changes, intended resignation, amendments to articles or regulations, own-funds reduction, mergers, acquisitions, reorganizations, branches, agencies, major outsourcing, name, address, legal form, trade-register data, control structure and other material changes.
Source reference: VASP Ordinance, Articles 47 through 50 and 56 through 60; commencement instrument Publicatieblad A 2025 No. 91, Article 1.
Assurance Assertions
- A VASP regulatory change-control register exists.
- CBCS consent and notification requirements are assessed before relevant changes proceed.
- Evidence of submissions, decisions and conditions is retained.
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-002 Assess Regulatory Change and Framework Impact, PROC-ECM-004 Manage Compliance Reporting and Escalation
- Controls: CTRL-MCT-001 Ensure Market Conduct Governance Permissions and Risk Are Current, CTRL-RMF-002 Ensure Risk Assessments Are Complete and 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; regulatory change and escalation are mapped while detailed ownership-change procedures 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 ownership-change implementation remains planned.