Bounty Management, Curator Responsibilities and Compliance Requirements

Preface

This compliance handbook serves as a guide for bounty curators managing bounties on behalf of Polkadot, a Swiss-based foundation. As a curator, you are entrusted with the responsibility to ensure that all bounties are managed transparently, ethically, and in compliance with applicable Swiss and international laws. This handbook outlines your duties, responsibilities, and the compliance requirements for managing bounties effectively, including conflict of interest policies, transaction documentation, anti-money laundering (AML) and know your customer (KYC) considerations, cross border payments and reporting obligations.

Failure to adhere to these guidelines may result in personal liability, reputational risks to Polkadot, and potential regulatory consequences.

1. Roles and Responsibilities of a Bounty Curator

As a bounty curator, you are responsible for:

1.1. Bounty Oversight

• Managing the lifecycle of a bounty, from proposal to payout.
• Ensuring that bounty proposals align with the goals and mission of Polkadot.
• Approving or rejecting submissions based on pre-defined criteria and in accordance with the bounty’s requirements.

1.2. Fair and Transparent Decision-Making

• Ensuring that all bounty decisions are made fairly, without favoritism or bias.
• Providing clear feedback to bounty participants regarding their submissions.

1.3. Compliance Management

• Adhering to the legal and regulatory requirements for token distributions globally.
• Conducting Know-Your-Customer (KYC) and Anti-Money Laundering (AML) checks, as required, especially for high-risk distributions (transactions >$10,000 or cumulative transfers >$100,000 over 12 months) or high-risk countries.

1.4. Recordkeeping

• Maintaining detailed records of all bounty-related activities, including proposals, payouts, and communications.