Purpose
Translate the VASP Ordinance into a testable BCMS requirement for controls specific to VASP service types.
Normative
Bitkaya shall maintain service-specific controls for each virtual asset service it offers, including exchange, custody or management, advice, order execution, order receipt and transmission, placement and issuance where applicable.
Descriptive
Service controls should address client eligibility and business policy, exchange rates and transaction details, custody agreements, position registers, client statements, client rights events, suitability and risk assessment for advice, best execution, order handling, conflicts, placement disclosures, issuer consent, white paper approval, fair allocation and equal treatment.
Source reference: VASP Ordinance, Articles 61 through 67; commencement instrument Publicatieblad A 2025 No. 91, Article 1.
Assurance Assertions
- Each offered virtual asset service has mapped service-specific controls.
- Service controls are tested against the applicable article requirements.
- Services not offered are documented as not applicable.
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-004 Perform Transaction Monitoring and Alert Review, PROC-AML-006 Apply Travel Rule and Counterparty VASP Due Diligence
- Controls: CTRL-MCT-003 Ensure Best Execution and Order Handling Are Controlled, CTRL-MCT-005 Ensure Client Assets and Custody Are Safeguarded, CTRL-RMF-005 Ensure New Products and Material Changes Are Approved, CTRL-COMM-003 Ensure Material Risks and Service Limitations Are Prominent, CTRL-COMM-005 Ensure External Communications Are Approved Versioned and Retained, CTRL-SAFU-002 Ensure Client Assets Are Segregated and Fully Matched, CTRL-SAFU-003 Ensure Client Asset Movements Are Authorized and Permitted, CTRL-SAFU-004 Ensure Client Assets Are Reconciled and Reported Accurately, CTRL-SAFU-005 Ensure Safeguarding Providers and Continuity Are Controlled, CTRL-SAFU-006 Ensure Custody Technology Access Keys and Recovery Are Secure, CTRL-SAFU-007 Ensure Safeguarding Terms and Client Communications Are Accurate
- Systems: SYS-KYT-001 Crystal Intelligence Blockchain Analytics
- Issues: ISS-KYT-001 Approve and Validate Crystal Intelligence Calibration, 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-KYT-002 Crystal Intelligence Calibration and Change Record, PUB-KYT-001 Odoo Pre-Trade and Post-Trade KYT Controls SOP, PUB-OTC-001 Bitkaya Principal OTC Service Flows Memo
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.