1. INTRODUCTION
Aegis DAO Foundation (“Foundation,” “we,” “our,” or “us”), a Cayman Islands foundation company, is committed to preventing, detecting, and responding to fraudulent activities in the execution of DAO decisions and protection of DAO assets. This Anti-Fraud Policy outlines our approach to maintaining operational integrity and protecting the Foundation from fraudulent behavior.
2. SCOPE AND APPLICATION
This Policy applies to:
- Foundation Directors
- Foundation Supervisor Council
- Authorized service providers
- Any party acting on behalf of the Foundation
3. FOUNDATION’S ROLE AND RESPONSIBILITIES
3.1 Primary Functions
The Foundation is responsible for:
- Executing DAO decisions
- Protecting DAO assets
- Managing relationships with custodians/exchanges
- Implementing governance decisions
3.2 Operational Boundaries
The Foundation:
- Does not interact directly with users
- Acts only upon DAO mandate
- Operates through regulated entities
- Maintains strict operational controls
4. FRAUD PREVENTION
4.1 Asset Protection Controls
- Multi-signature requirements
- Segregation of duties
- Authorization matrices
- Audit trails
- Transaction monitoring
4.2 Operational Controls
- Documented procedures
- Verification protocols
- Authority limits
- Regular audits
- System access controls
5. TYPES OF FRAUD RISKS
5.1 Internal Risks
- Unauthorized transactions
- Asset misappropriation
- False documentation
- Collusion with external parties
5.2 External Risks
- Cyber attacks
- Social engineering
- Third-party fraud
- Document forgery
6. MONITORING AND DETECTION
6.1 Transaction Monitoring
- Review of all asset movements
- Verification of DAO decisions
- Authorization checks
- Pattern analysis
6.2 System Controls
- Access monitoring
- Activity logging
- Suspicious activity detection
- Regular system audits
7. REPORTING PROCEDURES
7.1 Internal Reporting
Report suspected fraud to:
- Foundation Supervisor Council
- Compliance Officer
- Legal Department
7.2 Documentation Requirements
All reports must include:
- Detailed description
- Supporting evidence
- Timeline of events
- Affected assets/operations
8. INVESTIGATION PROCESS
8.1 Initial Assessment
- Evidence collection
- Risk evaluation
- Impact assessment
- Immediate controls
8.2 Investigation Steps
- Documentary review
- System analysis
- Interview relevant parties
- External expert engagement if needed
9. CORRECTIVE ACTIONS
9.1 Immediate Actions
- Asset protection measures
- System access restrictions
- Evidence preservation
- Stakeholder notification
9.2 Long-term Measures
- Control enhancement
- Policy updates
- Training improvements
- System upgrades
10. CONFIDENTIALITY
10.1 Information Handling
- Strict confidentiality
- Need-to-know basis
- Secure documentation
- Protected communications
10.2 Disclosure Restrictions
- Limited internal disclosure
- Regulatory reporting only
- Legal requirements
- DAO governance process
11. POLICY UPDATES
- Regular review
- Risk assessment updates
- Control enhancement
- Regulatory alignment
12. GOVERNING LAW
This Policy is governed by the laws of the Cayman Islands.
Updated on April 5, 2025