CRYPTO WALLET AUTHORIZATION FOR BUSINESS

Authorization Date: [DATE]

Document Number: [WALLET-AUTH-XXXX]

COMPANY INFORMATION

Company Name: [COMPANY LEGAL NAME] (the "Company")

Entity Type: ☐ Corporation ☐ LLC ☐ Partnership ☐ Other: [SPECIFY]

State/Country of Formation: [JURISDICTION]

EIN/Tax ID: [NUMBER]

Principal Address: [ADDRESS]

Primary Business Activity: [DESCRIPTION]

SECTION 1: PURPOSE AND AUTHORITY

1.1 Purpose

This Crypto Wallet Authorization ("Authorization") establishes the Company's official policies, procedures, and authorized personnel for managing cryptocurrency wallets, digital assets, and blockchain-based transactions conducted on behalf of the Company.

1.2 Corporate Authority

This Authorization is adopted pursuant to:

☐ Board of Directors Resolution dated [DATE]
☐ Member/Manager Resolution (LLC) dated [DATE]
☐ Partner Resolution dated [DATE]
☐ Delegated authority from [TITLE/PERSON]

1.3 Scope

This Authorization applies to:

☐ All Company-owned digital assets
☐ All wallets holding Company funds
☐ All personnel authorized to transact on Company's behalf
☐ All custodial arrangements with third parties
☐ Treasury management activities involving cryptocurrency

SECTION 2: AUTHORIZED WALLETS

2.1 Approved Wallet Registry

The following wallets are authorized for Company business:

Primary Treasury Wallets:

Operational Wallets:

Custodial Accounts:

2.2 Wallet Classifications

2.2.1 Cold Storage/Treasury Wallets:
- Purpose: Long-term storage of significant holdings
- Security: Multi-signature, hardware wallet, geographically distributed keys
- Access: Requires approval per Section 3
- Maximum Holdings: No limit

2.2.2 Hot/Operational Wallets:
- Purpose: Day-to-day transactions and operations
- Security: Multi-signature or single-signature with enhanced controls
- Maximum Holdings: $[AMOUNT] or [CRYPTOCURRENCY AMOUNT]
- Replenishment: From Cold Storage upon approval

2.2.3 Custodial Accounts:
- Purpose: [TRADING/STAKING/OTHER]
- Provider: Licensed and regulated custodian
- Insurance: Verified coverage of $[AMOUNT]

2.3 New Wallet Approval

New wallets may be established only with:

☐ Written approval from [AUTHORIZED PERSON/COMMITTEE]
☐ Documentation of business purpose
☐ Security assessment completion
☐ Addition to the Approved Wallet Registry

SECTION 3: AUTHORIZED PERSONNEL

3.1 Wallet Administrators

The following individuals are designated as Wallet Administrators with authority to manage wallet infrastructure:

3.2 Transaction Signers

The following individuals are authorized to sign/approve cryptocurrency transactions:

3.3 Multi-Signature Requirements

3.3.1 Transaction Approval Thresholds:

3.3.2 Multi-Sig Configuration:
- Treasury Wallet: [3] of [5] signers required
- Operational Wallet: [2] of [3] signers required

3.4 Key Custodians

The following individuals hold portions of multi-signature keys or recovery phrases:

3.5 Personnel Changes

3.5.1 Upon termination or role change of any Authorized Personnel:
- Immediately revoke wallet access
- Rotate any keys or credentials the person held
- Update multi-signature configurations
- Conduct security audit
- Update this Authorization

3.5.2 New personnel must complete:
☐ Background check
☐ Security training
☐ Acknowledgment of this Authorization
☐ Approval by [AUTHORIZING PERSON/COMMITTEE]

SECTION 4: TRANSACTION POLICIES

4.1 Authorized Transaction Types

The following transaction types are authorized:

☐ Treasury Management:
- Transfer between Company wallets
- Conversion between cryptocurrencies
- Stablecoin management

☐ Operational Payments:
- Vendor/contractor payments in cryptocurrency
- Employee compensation (where applicable)
- Service provider payments

☐ Investment Activities:
- Purchase of digital assets for treasury
- Staking and yield generation
- DeFi protocol participation

☐ Client/Customer Transactions:
- Receipt of cryptocurrency payments
- Refunds and credits
- Settlement transactions

4.2 Transaction Limits

4.2.1 Daily Limits:

4.2.2 Single Transaction Limits:

4.3 Approval Workflow

4.3.1 Standard Transaction Process:

1. Transaction initiator prepares request with:
   - Recipient address
   - Amount and asset type
   - Business purpose
   - Supporting documentation

2. Request submitted through [APPROVAL SYSTEM/PROCESS]

3. Required signers review and approve

4. Transaction executed and recorded

5. Confirmation documented

4.3.2 Emergency Transactions:

Emergency transactions exceeding normal authority may be executed if:
- Immediate action required to prevent loss
- Approved by [EMERGENCY AUTHORITY]
- Documented within [24] hours
- Reviewed at next regular meeting

4.4 Prohibited Transactions

The following are strictly prohibited without explicit Board approval:

☐ Personal transactions through Company wallets
☐ Transactions with sanctioned parties or addresses
☐ Speculative trading beyond approved treasury policy
☐ Transactions that circumvent approval requirements
☐ Mixing personal and Company funds
☐ Anonymous or privacy-coin transactions (unless specifically approved)

SECTION 5: SECURITY REQUIREMENTS

5.1 Key Management

5.1.1 Private Key Security:

☐ Private keys never stored in plain text
☐ Hardware wallets required for significant holdings
☐ Recovery phrases stored in geographically separate secure locations
☐ No private keys stored on internet-connected devices (for cold storage)
☐ Regular key rotation per [SCHEDULE]

5.1.2 Multi-Signature Implementation:

☐ Treasury wallets use [3-of-5] multi-signature
☐ No single person holds majority of keys
☐ Key holders in different geographic locations
☐ Hardware security modules (HSMs) where appropriate

5.2 Access Controls

5.2.1 Authentication Requirements:

☐ Two-factor authentication (2FA) mandatory for all accounts
☐ Hardware security keys required for [SPECIFY ACCOUNTS]
☐ Biometric authentication where available
☐ Regular password/credential rotation

5.2.2 Device Security:

☐ Dedicated devices for high-value transactions
☐ Approved hardware wallet models only
☐ Regular security updates
☐ No jailbroken or rooted devices

5.3 Network Security

☐ VPN required for wallet access
☐ Whitelisted IP addresses where possible
☐ Transaction signing from secure network only
☐ No public Wi-Fi for transactions

5.4 Physical Security

☐ Hardware wallets stored in [SECURE LOCATION]
☐ Access logged and monitored
☐ Fire and water protection
☐ Backup devices in [ALTERNATE LOCATION]

SECTION 6: RECORD KEEPING

6.1 Transaction Records

For each transaction, the following shall be recorded:

☐ Date and time (UTC)
☐ Transaction hash
☐ Wallet addresses (from and to)
☐ Asset type and amount
☐ USD value at time of transaction
☐ Business purpose
☐ Authorizing personnel
☐ Supporting documentation

6.2 Wallet Records

Maintain records of:

☐ All authorized wallets and addresses
☐ Key holder assignments
☐ Security configurations
☐ Access logs
☐ Configuration changes

6.3 Retention Period

Records shall be retained for:

☐ Transaction records: [7] years minimum
☐ Wallet configurations: Life of wallet plus [3] years
☐ Authorization documents: [7] years minimum
☐ Tax records: Per IRS requirements (minimum [7] years)

6.4 Tax Reporting

6.4.1 The Company shall maintain records sufficient for:
- IRS Form 8949 reporting
- Cost basis tracking (FIFO/LIFO/Specific ID)
- Form 1099-DA issuance (as required)
- State tax reporting

6.4.2 Responsibility: [FINANCE DEPARTMENT/CFO/ACCOUNTANT]

SECTION 7: MONITORING AND COMPLIANCE

7.1 Regular Monitoring

☐ Daily: Review of wallet balances and recent transactions
☐ Weekly: Reconciliation of all wallets
☐ Monthly: Full compliance audit
☐ Quarterly: Security assessment
☐ Annually: External audit (if applicable)

7.2 Alerts and Notifications

Configure alerts for:

☐ Any transaction above $[AMOUNT]
☐ Transactions to new addresses
☐ Multiple transactions in short period
☐ Unusual transaction patterns
☐ Failed authorization attempts

7.3 Compliance Requirements

7.3.1 Regulatory Compliance:

☐ FinCEN MSB registration (if applicable)
☐ State money transmitter licenses (if applicable)
☐ AML/KYC procedures for client transactions
☐ OFAC sanctions screening
☐ Suspicious activity reporting

7.3.2 Internal Compliance:

☐ Segregation of duties
☐ Regular policy reviews
☐ Employee training
☐ Incident response procedures

7.4 Audit Requirements

7.4.1 Internal audits shall be conducted [QUARTERLY/ANNUALLY] to verify:
- Compliance with this Authorization
- Accuracy of wallet records
- Proper authorization of transactions
- Security control effectiveness

7.4.2 External audits may be required for:
- Financial statement audits
- SOC 2 compliance
- Regulatory examinations

SECTION 8: INCIDENT RESPONSE

8.1 Incident Types

The following are considered security incidents:

☐ Suspected unauthorized access
☐ Lost or stolen keys/devices
☐ Unusual transactions
☐ Phishing or social engineering attempts
☐ Security breaches at custodians
☐ Smart contract vulnerabilities affecting holdings

8.2 Incident Response Procedures

8.2.1 Immediate Actions (within 1 hour):
1. Notify [INCIDENT RESPONSE LEAD]
2. Secure affected wallets (freeze if possible)
3. Assess scope of potential compromise
4. Begin incident log

8.2.2 Short-Term Actions (within 24 hours):
1. Rotate compromised credentials
2. Move assets to secure wallets if necessary
3. Notify relevant personnel and stakeholders
4. Engage security experts if needed

8.2.3 Recovery Actions:
1. Root cause analysis
2. Implement preventive measures
3. Update security procedures
4. Document lessons learned

8.3 Incident Reporting

Report incidents to:
- Internal: [SECURITY OFFICER/COMMITTEE]
- External (if required): [LAW ENFORCEMENT/REGULATORS]
- Insurance: [INSURANCE PROVIDER]

SECTION 9: BUSINESS CONTINUITY

9.1 Backup Procedures

☐ Recovery phrases backed up in [LOCATIONS]
☐ Hardware wallet backups available
☐ Key shards distributed geographically
☐ Documented recovery procedures

9.2 Succession Planning

If a key holder becomes unavailable:

☐ Backup key holders designated
☐ Recovery procedures documented
☐ Time lock or social recovery mechanisms implemented
☐ Regular succession drills conducted

9.3 Disaster Recovery

In case of catastrophic event:

1. Activate backup key holders
2. Access backup recovery phrases
3. Restore wallets on new hardware
4. Verify all asset balances
5. Resume operations

SECTION 10: AMENDMENTS AND UPDATES

10.1 Amendment Process

This Authorization may be amended by:

☐ Board of Directors resolution
☐ Majority vote of [AUTHORIZED GROUP]
☐ Written approval of [AUTHORIZED PERSON]

10.2 Review Schedule

This Authorization shall be reviewed:

☐ Annually, at minimum
☐ After any security incident
☐ When significant changes occur to Company's crypto activities
☐ When regulatory requirements change

10.3 Version Control

SECTION 11: ACKNOWLEDGMENT

11.1 Personnel Acknowledgment

All Authorized Personnel must sign the following acknowledgment:

AUTHORIZED PERSONNEL ACKNOWLEDGMENT

I, the undersigned, acknowledge that I have received, read, and understand the Company's Crypto Wallet Authorization. I agree to:

☐ Comply with all policies and procedures contained herein
☐ Maintain the security of any keys, credentials, or access granted to me
☐ Report any security concerns or incidents immediately
☐ Not share access credentials or recovery phrases
☐ Act only within my authorized scope
☐ Keep this Authorization and any access information confidential

Signature: _________________________________

Name: [NAME]

Title: [TITLE]

Date: [DATE]

11.2 Corporate Acknowledgment

CORPORATE RESOLUTION/AUTHORIZATION

The undersigned, being duly authorized officers/representatives of [COMPANY NAME], hereby certify that:

1. This Crypto Wallet Authorization has been duly adopted by [BOARD/MEMBERS/PARTNERS]

2. The persons named herein are authorized to act on behalf of the Company regarding cryptocurrency and digital assets

3. This Authorization supersedes any prior wallet authorization policies

Officer/Authorized Representative:

Signature: _________________________________

Name: [NAME]

Title: [TITLE]

Date: [DATE]

Second Officer/Authorized Representative (if required):

Signature: _________________________________

Name: [NAME]

Title: [TITLE]

Date: [DATE]

EXHIBIT A: APPROVED HARDWARE AND SOFTWARE

A.1 Approved Hardware Wallets

A.2 Approved Software Wallets

A.3 Approved Custodians

REGULATORY NOTICES

FinCEN NOTICE: Depending on the nature of the Company's activities, registration as a Money Services Business (MSB) may be required. Businesses that exchange, transmit, or administer cryptocurrency may be classified as money transmitters under federal and state law.

TAX NOTICE: Cryptocurrency transactions are taxable events. The Company must maintain adequate records for tax reporting purposes. Beginning in 2025, cryptocurrency brokers must issue Form 1099-DA.

STATE LICENSING: Many states require money transmitter licenses for businesses engaged in cryptocurrency transmission. New York requires a BitLicense for virtual currency business activity. California's Digital Financial Assets Law becomes effective in 2026.

INTERNAL CONTROLS: This Authorization is designed to implement appropriate internal controls for digital asset management. Companies should consult with legal and compliance professionals to ensure adequate controls for their specific activities.

This template is provided for informational purposes only and should be reviewed and customized by qualified legal and compliance professionals familiar with cryptocurrency regulations and corporate governance requirements in your jurisdiction.