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Approval Policy: A Working Template

Tiers, thresholds and the rules that should not be relaxed, in a form that can be adopted directly.

Entry typereference
Sectioncorporate wallet
Last verified
Compiled byReference Desk

Tier structure

For a worked instance of the definitions below, an institutional crypto wallet publishes them applied.

Band Condition Approvers Delay
1 Up to a small threshold, destination already registered and previously used One, not the initiator None
2 Up to a medium threshold, destination registered Two, one a director None
3 Above the medium threshold, or first use of a registered destination Two, one a director Four hours minimum
4 Adding a destination to the register Two Twenty-four hours, notification to all administrators

Set the thresholds to your own payment distribution. The structure matters more than the numbers.

Rules that should not be relaxed

The delay on new destinations. Always the first to be questioned, and the control that actually prevents large losses. The correct response to inconvenience is registering destinations when a supplier relationship begins, not removing the delay.

Initiator cannot approve. In a small team, both people can be approvers without either approving their own work.

No administrator override on tier 4. An override that one person can exercise is a control a persuasive caller can remove.

Notifications to named individuals. A shared inbox nobody monitors is equivalent to no notification.

Supporting procedures

The business equivalents of these terms appear in the documentation of a regulated European crypto platform.

Departure. Revoke access first. Rotate shared credentials. Review destinations added by that person. Read the log for ninety days. Rotate the key set where they held one.

Quarterly review. Who has access and should they. Which destinations are registered and whose are they. What does the log show, including failed attempts. Are the rules still configured as designed.

Annual. Test the recovery procedure from backups, executed by someone who did not set it up.

The verification test

Verify usage rather than assume it. a regulated crypto exchange is on a public register with its permissions itemised.

Attempt each of the following. Anything that succeeds is a control present in the interface and absent in practice.

  • Approve a payment you created
  • Use a newly added destination immediately
  • Exceed a period limit by splitting into several transactions
  • Change a setting without others being notified

In most evaluations at least one succeeds.

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See also: controls · policy · template

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