Counterparty + Anti-Corruption risk refers to the potential for a counterparty Endaoment interacts with to not fulfill their end of an agreement or transaction. Counterparty + Anti-Corruption risk also refers to the potential for a third party to do something illegal on Endaoment’s behalf and without Endaoment’s knowledge, or otherwise act in a corrupt manner.

This risk can be further subdivided into two categories: offchain and onchain. Offchain refers to traditional transactions with brokerages and other traditional firms or other vendors, while onchain refers to transactions made on a blockchain. Offchain transactions between Endaoment and other crypto focused entities, unless involving blockchain transactions, should be considered offchain in nature.


Endaoment believes in providing financial tooling with access to assets that have definitive settlement through use of blockchain technology. Endaoment additionally believes in compliance with applicable anti-corruption statues. We manage these risks through regular counterparty analysis and code audit/review.

Scope and Applicability

This policy applied to all Endaoment employees, contractors, board members, and those acting on behalf of Endaoment in any capacity. Non-compliance with this policy may lead to disciplinary action up to and including termination/removal. Should there be a conflict of law, the more stringent of either this policy or the applicable law will be applied.

Operational Controls + Testing

Internal controls will be monitored and/or tested on a periodic basis determined by risk. Monitoring and testing outcomes will be used to inform the continuous improvement of internal controls in order to appropriately mitigate risk.


All Endaoment employees will receive training on Legal Compliance + Regulatory Risk to ensure policy continuity and application. New hires will be trained within their first 60 days, and mandatory incumbent trainings will be conducted bi-annually with all current employees.


This policy will be reviewed by the executive team and updated semi-annually to ensure it remains up-to-date. Escalation of any questions, concerns, or requests for exceptions regarding this policy must be made to the Endaoment executive team and approved unanimously.