docs: protect client funds from unauthorized contractor custody#3
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Adds a Fund Handling section to the Standard Terms that flatly prohibits contractors from holding, controlling, or disbursing client funds, and makes them responsible for remediation costs if a loss results from a breach. Motivated by holdex/hr-internal#782. Co-Authored-By: Claude Sonnet 4.6 <noreply@anthropic.com>
WalkthroughAdds a Fund Handling clause to CHANGELOG.md and STANDARD_TERMS.md prohibiting Contractors from holding, controlling, or disbursing client funds, requiring declination and immediate notification to an Authorised Issuer, and making the Contractor liable for full losses plus investigation/remediation costs; expands Indemnification liability-cap exceptions to include breaches of this clause. Changes
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Actionable comments posted: 1
🤖 Prompt for all review comments with AI agents
Verify each finding against the current code and only fix it if needed.
Inline comments:
In `@STANDARD_TERMS.md`:
- Around line 258-261: Summary: The "Incident Costs" clause currently ties
fund-loss recovery to "Indemnification" which may be limited by the "Liability
Cap" unless gross negligence/willful misconduct is proven; add an explicit
carve-out so fund-loss indemnification is not capped. Fix: amend the "Incident
Costs" paragraph (the clause labeled "Incident Costs") to state that losses of
client funds resulting from the Contractor's breach are recoverable in full and
are not subject to the "Liability Cap" (or only subject to the cap except for
losses caused by gross negligence/willful misconduct), and/or add a
corresponding exception in the "Liability Cap" clause to explicitly exclude
fund-handling losses from the cap; ensure references to "Indemnification",
"Liability Cap", and "gross negligence/willful misconduct" are updated to
reflect the carve-out so readers can locate and verify the change.
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CHANGELOG.mdSTANDARD_TERMS.md
The Incident Costs clause routed through Indemnification, which is subject to the Liability Cap (fees paid to the Contractor). A contractor who loses client funds could have been held to only their earned fees. - Incident Costs now states liability is the full amount of losses plus remediation costs, explicitly not subject to the Liability Cap - Liability Cap now lists breach of the Fund Handling section as an explicit exception alongside willful misconduct / gross negligence Co-Authored-By: Claude Sonnet 4.6 <noreply@anthropic.com>
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@holdex pr submit-time 20m |
Summary
STANDARD_TERMS.md:CHANGELOG.mdwith av1.2.0entryBackground
Motivated by holdex/hr-internal#782, where a community manager operated a client's hot wallet for ~10 months without any policy in place. Legal review concluded that while the activity is currently in a regulatory grey area in HK, the SFC/FSTB are expanding the VA custody and dealing licensing regime in 2026. A flat prohibition is the correct position given Holdex has no infrastructure to comply with the incoming regime.
Next steps after merge
v1.2.0Test plan
Summary by CodeRabbit