Purpose
Translate the VASP Ordinance and commencement landsbesluit into a testable BCMS requirement for effective-date management, transitional obligations and non-effective provisions.
Normative
Bitkaya shall maintain a VASP effective-date and transitional-obligation register that identifies effective provisions, excluded provisions, transitional notifications and any later commencement instruments.
Descriptive
The register should record that the VASP Ordinance entered into force on 2025-07-01, except Article 15(1)(c)-(d) and Article 37(2)(b). It should track transitional notifications for existing VASPs, CBCS and Financial Intelligence Unit notifications where applicable, licence or exemption applications treated as transitional filings, and continuing compliance during the period between notification and CBCS decision.
Source reference: VASP Ordinance, Articles 134 through 136; commencement instrument Publicatieblad A 2025 No. 91, Article 1.
Assurance Assertions
- The VASP effective-date position is documented.
- Excluded provisions are not treated as effective until a later instrument is identified.
- Transitional filings, if applicable, are evidenced and tracked through CBCS decision.
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-006 Apply Travel Rule and Counterparty VASP Due Diligence, PROC-AML-010 Review AML Policy and Proportionality Implementation
- Controls: not yet assigned; tracked under ISS-VASP-001
- 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 transitional implementation 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 transitional implementation remains planned.