To start 2022 on a positive note, I would like to announce that as of today Open Web Sandbox has its own AML Compliance and Due Diligence Playbook entirely compiled by Legal Guild.
In this overview, I would like to shed light on:
- The nature of the collaboration OWS had with Legal Guild in 2021
- Give a summary on the identified risk assessment made specifically for the OWS
- Elaborate on the brand new AML / Compliance / Due Diligence Playbook
- Update on the OWS Privacy Policy
1. Context
Back in September, OWS opened up a conversation with Legal Guild regarding the potential need to set up KYC policy since OWS operates community funds to distribute to contributors for tasks undertaken on a monthly basis in support of the NEAR ecosystem. We sought to have a risk management tool that would be used to protect the OWS from various associated risks.
Considering that we work with contributors from all over the globe and the issue of cryptocurrencies being in the legal grey area, we saw this collaboration as the first step to a workable legal disclaimer. In the last couple of months, we have been communicating OWS legal needs and concerns to Legal Guild while @SChamat together with his team were attentively listening, doing the necessary research about the complex matter as such but also inquiring into the specifics of OWS and communicating back to us confirming each time.
Today, we are proud to share the results with the community and we are hoping that all the work done by Legal guild will be taken seriously, spread across the community and applied where possible. The primary goal was to set up a legal policy for OWS but today this documentation is accessible to everyone to benefit from it. VoilĂ !
2. Identified Risk Assessment (FOR OWS)
Legal Guild used OWS goals and needs to create a use-case scenario that gives high-level recommendations on how to identify and tackle specific risk levels. Concrete considerations were included on the actions to perform that can also be used by other communities or projects with similar issues.
To check the OWS Risk Assessment here.
3. AML / Compliance / Due diligence Playbook (GENERAL for everyone)
This is a more general guide compiled by Legal Guild for the NEAR Community.
This document is not focused on the OWS, but it was created based on OWS concerns. This playbook is a great opener to a legal conversation various Guild/Projects might be having these days.
To check AML Playbook here
4. OWS Privacy Policy (for OWS)
Lastly, Legal guild has prepared the first draft for OWS Privacy Policy and recommendation on how to implement it on the OWS website. The final bits of the draft are being currently finalized and we will add the website plug-in in the coming days.
Acknowledgement
In the context of the new payout processes, the legal wrapper of every entity becomes extremely important. This being said, I would like to express my personal gratitude to @SChamat and the members of his guild who spent a considerable amount of time to share first learnings and discoveries relevant not only to OWS but for all the NEAR entities that pose similar questions.
I would also like to thank @mecsbecs for playing an advisory role on behalf of NF and coordinating this collaboration in the right direction when needed.