LexDAO Memo: Bankless DAO
__codeslaw, not legal advice

Bankless DAO is an online community using digital tokens (BANK, 0x2d94/a198) to coordinate and support Bankless media properties (newsletter, podcast, youtube channel) with a vision to "drive[] adoption of bankless money systems like Ethereum, Bitcoin and DeFi...." 

/// Engineering
BANK is a fungible (erc20) token extended for minting and COMP-style delegate voting. The community treasury that receives BANK vesting, controls vesting recipients and minting is composed of a Gnosis SAFE with 4/7 signatures required to execute contract state changes. BANK 'snapshot' proposals signal on such multisig. transactions.

/// Distribution
1 billion BANK was retroactively airdropped to individual Bankless media accounts and community treasury contracts (multisig/vesting), where BANK serves as the 'native governance token' of Bankless DAO with an initial mandate to govern further BANK grants. 

/// Proposals 
The genesis BANK proposal was overwhelmingly ratified by snapshot vote among BANK holders on May 7, 2021, and authorized a grant of 250 million BANK (25% of supply) vested over 3 years with a 6-month cliff to Bankless, LLC, the "core media node" of BANK led by founding contributors to Bankless media properties and the "bankless meme". 

// Entities
Bankless, LLC is registered in Virginia and uses a Gnosis SAFE multisig. for its own bankless operations and BANK grant. Additional aligned media properties include Bankless FR & Bankless RU, which have separate contributors and may form legal entities in the future.

X LexDAO Comments X
Since BANK conveniently already has on-chain voting functionality and could be integrated into platforms that support COMP-style proposals and execution (withtally.com), contract technical risks and legal liabilities that might emerge for multi-sig. operators in the conduct of their duties (incl. implied) could be mitigated by deploying a 'Governor' and 'Timelock' contract that is entirely controlled by BANK delegate voting, and likewise, transferring BANK minter, vesting, and other contract admin. to such Governor contracts. The question of forming an umbrella legal entity that is subject to BANK voting is, needless to say, complex from the scope of token distribution and variety of value-add participants, but seems interesting to revisit after the working relationships of BANK entities and token holders become more clear.
 
For now, multi-sig participants might contain their BANK governance roles and outcomes of signatures by wrapping their wallet with an LLC or other limited liability 'personality'. Legal engineering solutions that provide crypto-native legal registrations include LexDAO's Ricardian LLC network (ricardianllc.eth), Etherize company services (etherize.io), and Otoco company suite (otoco.io). Similarly, a multi-sig itself can help shield its own admin. of contracts by operating through a limited liability vehicle. 

On the receiving end of BANK governance, individual BANK grant recipients and teams might also benefit from using separate legal personalities to conduct BANK-related business, as they will likely involve legal concerns over hiring, ownership, revenue splits and working with other BANK entities as operations scale. Further, as BANK will be used to finance and secure alignment between such grantees and the BANK DAO 'mothership', keeping everything on-chain (as convenient) by deploying a Gnosis SAFE, Moloch DAO, Aragon, Colony or other 'coordination contract' with a legal wrapper seems efficient, and well, a *bankless* solution for grant-bootstrapped ventures (see solutions outlined in preceding paragraph).