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| 1 | +# Wallet Address Change Policy |
| 2 | + |
| 3 | +**1. Policy Title:** Wallet address change policy |
| 4 | + |
| 5 | +**2. Version:** 1.0 |
| 6 | + |
| 7 | +**3. Effective Date:** 03/09/2025 |
| 8 | + |
| 9 | +**4. Review Date:** 03/09/2026 |
| 10 | + |
| 11 | +**5. Policy Owner:** Head of Procurement  |
| 12 | + |
| 13 | +**6. Policy Sponsor:** Director of Operations |
| 14 | + |
| 15 | +*** |
| 16 | + |
| 17 | +**7. Purpose:** |
| 18 | + |
| 19 | +* To ensure the secure and verified update of wallet addresses listed in vendor contracts after contract execution. This policy protects against unauthorized changes and potential fraud by enforcing a standardized identity verification process prior to approving any wallet address modification. |
| 20 | + |
| 21 | +**8. Scope:** |
| 22 | + |
| 23 | +* This policy applies to all vendors with active contracts who request to change the wallet address specified in their contract after it has been signed. |
| 24 | +* Exclusions: This policy does not apply to the initial submission of wallet addresses during the contracting phase or to vendors whose contracts do not involve cryptocurrency payments. |
| 25 | + |
| 26 | +**9. Principles:** |
| 27 | + |
| 28 | +This policy is grounded in the principles of: |
| 29 | + |
| 30 | +* Security – preventing unauthorized or fraudulent wallet address changes. |
| 31 | +* Verification – ensuring only authorized representatives of the vendor can initiate and approve changes. |
| 32 | +* Accountability – maintaining clear audit trails for all wallet address changes. |
| 33 | +* Transparency – consistent communication and documentation of all changes. |
| 34 | + |
| 35 | +**10. Definitions:** |
| 36 | + |
| 37 | +* Wallet Address: Represents a blockchain wallet used for receiving payments. |
| 38 | +* KYC (Know Your Customer): A process of identity verification to confirm the legitimacy of the requestor. For more information, you can read the [Intersect Due Diligence Policy](https://docs.intersectmbo.org/legal/policies-and-conditions/intersect-administration-policies/due-diligence-policy). |
| 39 | +* Authorized Representative: A person identified in the contract or via KYC who has legal authority to act on behalf of the vendor. |
| 40 | +* Verification Call: A phone call conducted to confirm the identity and intent of the individual requesting the wallet address change. |
| 41 | + |
| 42 | +**11. Policy Statements:** |
| 43 | + |
| 44 | +* Vendors may request a wallet address change after contract execution through the defined process.  |
| 45 | +* All wallet address change requests must be accompanied by a completed KYC via Sumsub. |
| 46 | +* The KYC form must include a valid phone number of an authorized representative. |
| 47 | +* A member of the Operational Services team will conduct a verification call to confirm the requestor’s identity and the change request. |
| 48 | +* No wallet address changes will be accepted via email or messaging platforms without full verification. |
| 49 | +* Changes will only be processed after successful verification and documentation. |
| 50 | +* It is at Intersects discretion to process wallet address change requests, circumstances exist where this may not be operationally or technically possible.  |
| 51 | +* All wallet address change requests and confirmations will be logged and retained for audit purposes. |
| 52 | + |
| 53 | +**12. Roles and Responsibilities:** |
| 54 | + |
| 55 | +**Vendor:** |
| 56 | + |
| 57 | +* Initiates the wallet address change request via sending an email cc’ing in [[email protected]](mailto:[email protected]) and [email protected]. |
| 58 | +* Submits the completed KYC form including the authorized phone contact. |
| 59 | +* Ensures availability for the verification call. |
| 60 | +* Submits new wallet address using Intersects [wallet request form.](https://forms.gle/VgX7nZbcnnXL9o99A) |
| 61 | + |
| 62 | +**Operations / Payments Team:** |
| 63 | + |
| 64 | +* Procurement sends the KYC form to the vendor upon request. |
| 65 | +* Conducts the verification call. |
| 66 | +* Confirms the identity of the authorized representative. |
| 67 | +* Checks the new wallet address has been submitted via the google form and checked internally. |
| 68 | +* Updates the wallet address in internal systems post-verification and relays to the operational services team for the vendor smart contract. |
| 69 | +* Logs all communications and updates for audit records. |
| 70 | +* If the call fails or the requestor cannot be verified: |
| 71 | +* The change is rejected, and the vendor is notified. |
| 72 | +* All records are stored securely for auditing. |
| 73 | + |
| 74 | +**13. Monitoring and Compliance:** |
| 75 | + |
| 76 | +* All wallet address changes will be monitored and logged. |
| 77 | +* Periodic internal audits will verify adherence to this policy. |
| 78 | +* Fraudulent or unverified requests will be reported and may lead to contract termination or legal action. |
| 79 | + |
| 80 | +**14. Review and Amendment:** |
| 81 | + |
| 82 | +* This policy will be reviewed annually or upon significant changes to vendor engagement processes, risk management protocols, or applicable regulations. |
| 83 | +* Amendments require approval from the Policy Owner and the Policy Sponsor. |
| 84 | + |
| 85 | +**15. Related Documents/References:** |
| 86 | + |
| 87 | +[Intersect Due Diligence Policy](https://docs.intersectmbo.org/legal/policies-and-conditions/intersect-administration-policies/due-diligence-policy). |
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