Freeze & Compliance
Policy
This page captures the current public posture for KYC, sanctions, freezes, and emergency pause powers based on the deployed contract model and the published production topology. It also marks the legal and operational pieces that still require final policy approval.
01 Contract Model
The compliance registry contract currently stores four status fields per account:
kycApproved, sanctioned, frozen, and kycExpiresAt.
- KYC approval is required for mint and redeem eligibility.
- Sanctioned or frozen accounts are blocked.
- Emergency pause powers exist separately through contract pause roles.
The current repository models compliance status on-chain for accounts, but it does not yet publish a dedicated public freeze-event archive page or formal jurisdiction list.
02 Authority
The production topology assigns COMPLIANCE_ROLE to the compliance operator or backend for account-level KYC, sanctions, and freeze state changes. Emergency pause powers are assigned separately to the emergency multisig on relevant contracts.
| Action | Current source of authority |
|---|---|
| KYC status update | Compliance role |
| Sanction status update | Compliance role |
| Freeze status update | Compliance role |
| Emergency contract pause | Emergency multisig via pause roles |
The whitepaper promises documented legal and security constraints, public disclosure, and multi-signature discipline for freeze actions. The final operational workflow for that promise is still not fully published here.
03 Disclosure
The public commitment is that freeze actions should not remain opaque. At minimum, launch-time policy should include a public disclosure path that records the fact of a freeze event and the category of rationale where legally permissible.
- Public freeze event registry: not yet implemented in this website repository.
- Public rationale taxonomy:
TBD. - Disclosure timing after a freeze:
TBD.
04 Process Notes
Based on the current contract design and public topology, a practical public process description should distinguish between account-level compliance restrictions and system-wide emergency pause actions.
- Account-level restrictions are expressed through the compliance registry.
- Emergency pause actions use contract pause roles and can degrade public
/statusimmediately. - Any future public incident page should preserve that distinction.
05 Open Items
- Jurisdiction blocklist and OFAC implementation details remain
TBD. - KYB document requirements and onboarding evidence requirements remain
TBD. - Appeal and unfreeze review workflow remain
TBD. - Public disclosure timing and exact reporting format remain
TBD.