Last Updated: December 9, 2024
1. INTRODUCTION
Aegis DAO Foundation (“Foundation,” “we,” “our,” or “us”), a Cayman Islands foundation company, is committed to complying with all applicable sanctions laws and regulations in the execution of DAO decisions and protection of DAO assets. This Sanctions Compliance Policy outlines our approach to ensuring adherence to international sanctions regimes.
2. FOUNDATION’S ROLE AND SCOPE
2.1 Core Functions
The Foundation is responsible for:
- Executing DAO decisions
- Protecting DAO assets
- Managing institutional relationships
- Implementing governance decisions
2.2 Operational Boundaries
The Foundation:
- Does not interact directly with users
- Acts only upon DAO mandate
- Operates through regulated entities
- Maintains institutional relationships
3. SANCTIONS COMPLIANCE FRAMEWORK
3.1 Applicable Sanctions Regimes
We comply with sanctions imposed by:
- United Nations Security Council
- Cayman Islands
- European Union
- UK Financial Sanctions
- Other applicable authorities
3.2 Compliance Requirements
Core elements include:
- Risk assessment
- Due diligence
- Monitoring
- Reporting
- Documentation
4. INSTITUTIONAL RELATIONSHIPS
4.1 Due Diligence
Required for relationships with:
- Custodians
- Exchanges
- Banking partners
- Service providers
4.2 Ongoing Monitoring
Regular review of:
- Existing relationships
- Transaction patterns
- Regulatory status
- Compliance updates
5. RISK ASSESSMENT
5.1 Risk Categories
Assessment of:
- Geographic risks
- Relationship risks
- Transaction risks
- Service risks
5.2 Risk Mitigation
Implementation of:
- Control measures
- Monitoring systems
- Review procedures
- Documentation requirements
6. SCREENING PROCEDURES
6.1 Initial Screening
Required for:
- New institutional relationships
- Service providers
- Major transactions
- Contract parties
6.2 Ongoing Screening
Regular screening of:
- Existing relationships
- Transaction flows
- Corporate structures
- Ultimate beneficial owners
7. PROHIBITED ACTIVITIES
7.1 General Prohibitions
The Foundation shall not:
- Engage with sanctioned entities
- Process prohibited transactions
- Circumvent sanctions
- Facilitate violations
7.2 Specific Restrictions
Prohibition on:
- Sanctioned jurisdictions
- Designated persons
- Restricted activities
- Prohibited services
8. COMPLIANCE PROCEDURES
8.1 Transaction Review
Assessment of:
- Source of funds
- Transaction purpose
- Counterparties
- Documentation
8.2 Documentation Requirements
Maintenance of:
- Due diligence records
- Transaction records
- Screening results
- Compliance reports
9. REPORTING AND ESCALATION
9.1 Internal Reporting
Report to:
- Foundation Supervisor Council
- Compliance Officer
- Legal Department
9.2 External Reporting
When required to:
- Regulatory authorities
- Financial Intelligence Unit
- Law enforcement
- Relevant regulators
10. TRAINING AND AWARENESS
10.1 Training Program
Regular training on:
- Sanctions requirements
- Compliance procedures
- Red flags
- Reporting obligations
10.2 Documentation
Maintenance of:
- Training records
- Attendance logs
- Assessment results
- Understanding confirmation
11. AUDIT AND REVIEW
11.1 Internal Audit
Regular review of:
- Compliance procedures
- Documentation
- Risk assessments
- Control effectiveness
11.2 External Audit
Periodic review by:
- Independent auditors
- Compliance consultants
- Legal advisors
- Specialist firms
12. RECORD KEEPING
12.1 Required Records
Maintenance of:
- Due diligence files
- Transaction records
- Screening results
- Compliance reports
12.2 Retention Period
Records kept for:
- Minimum 5 years
- Extended if required
- Regulatory compliance
- Audit purposes
13. ENFORCEMENT AND PENALTIES
13.1 Internal Consequences
May include:
- Disciplinary action
- Contract termination
- Legal action
- Regulatory reporting
13.2 External Consequences
Understanding of:
- Criminal penalties
- Civil fines
- Regulatory actions
- Reputational impact