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Synthetic Users Transactional Authority Levels
Document ID: CRA-33.3.1-TAL-001
Version: 1.0
Effective Date: March 25, 2026
Last Updated: March 25, 2026
Owner: CEO — Kwame Ferreira
Approved By: CEO — Kwame Ferreira
Classification: Internal – Confidential
CRA Control: CRA 33.3.1
1. Purpose
This document formally defines who within Synthetic Users, Inc. is authorized to approve financial commitments, operational decisions, and system-level actions — by role, individual, and threshold. It ensures that all material transactions and decisions are subject to appropriate authorization and that no single individual can unilaterally approve transactions beyond their designated authority level.
2. Scope
This document applies to:
- All financial commitments (expenditure, contracts, subscriptions)
- All operational authority delegations (hiring, vendor onboarding, system access)
- All system-level privileged actions
- All employees, contractors, and directors of Synthetic Users, Inc.
3. Organizational Roles
| Role | Individual | Reports To |
|---|---|---|
| Chief Executive Officer (CEO) | Kwame Ferreira | Board / Founders |
| Chief Financial Officer (CFO) | Zumbi Ferreira | CEO |
| Chief Technology Officer (CTO) | Artur Ventura | CEO |
| Head of Research / Operations | Samantha Reis | CEO |
| Senior Engineer | Davi Campos | CTO |
| Engineer | Tiago Coelho | CTO |
| Operations Associate | Joao Rocha | Head of Operations |
4. Financial Authority
4.1 Expenditure Approval Thresholds
| Transaction Value | Required Approver(s) |
|---|---|
| Up to $1,000 | CTO (technology) or CFO (operations/finance) |
| $1,001 – $10,000 | CTO + CFO joint approval |
| $10,001 – $50,000 | CEO approval required |
| Above $50,000 | CEO + CFO joint approval |
| Any amount — external legal or regulatory commitments | CEO only |
4.2 Specific Financial Transaction Authority
| Transaction Type | Authorized By |
|---|---|
| Employee payroll | CFO (Zumbi Ferreira) |
| Contractor invoices | CTO (technology contractors) or CFO (other) |
| SaaS / software subscriptions | CTO up to $1,000/month; CEO above |
| Cloud infrastructure (AWS, Render) | CTO up to $10,000/month; CEO above |
| Vendor contracts (new) | CEO; CFO for renewals below $10,000 |
| Client refunds | CFO up to $5,000; CEO above |
| Bank transfers | CFO initiates; CEO authorizes for amounts > $10,000 |
5. Operational Authority
| Activity | Authorized By | Notes |
|---|---|---|
| New hire offer letters | CEO | All permanent hires |
| Contractor engagement (< 90 days) | CTO (technical) or CEO (other) | Must include written SOW |
| Contractor engagement (≥ 90 days) | CEO | Requires CFO budget confirmation |
| Employee termination | CEO | CFO notified for payroll |
| Performance improvement plans | CEO + relevant department lead | |
| New vendor onboarding | CTO (technical vendors) or CFO (other) | DPA required where applicable |
| Vendor offboarding | CTO (technical) or CFO (other) | Confirm data deletion |
| Customer contract execution | CEO only | Per Signing Authority Policy |
| NDA execution | CEO only | Per Signing Authority Policy |
| JPMC-specific commitments | CEO; CTO for technical commitments within existing contract scope | |
| Press releases / public statements | CEO | |
| Regulatory filings | CEO + Legal advisor |
6. System-Level Authority
| System Action | Authorized By | Requires Second Approver? |
|---|---|---|
| Production database access | CTO | Yes — CEO for break-glass |
| Production deployment (planned) | Engineering Lead | No — via CI/CD |
| Emergency production rollback | CTO | No — immediate action permitted; post-event review required |
| New LLM provider enablement | CTO | Yes — CEO informed |
| API key creation (production) | CTO | No — logged automatically |
| API key rotation (production) | Engineering Lead | No |
| Infrastructure scaling changes | CTO | No — within approved budget envelope |
| Security group / firewall changes | CTO | No — reviewed in weekly security standup |
| New user provisioning (internal admin) | CTO | No |
| Admin privilege grant (internal) | CTO | Yes — CEO approval for financial system access |
| JPMC-specific system configuration | CTO | Yes — JPMC must confirm in writing for material changes |
7. Exception Process
When a transaction or action falls outside the defined authority levels or requires urgent action:
- The requesting party documents the exception in writing, including the nature of the request, the business justification, and the time constraint
- The next-level authority reviews the exception request
- If approved, the approval is recorded in the company's document management system with date and approver identity
- The exception is reviewed at the next quarterly governance meeting to determine if the authority matrix should be updated
- All exceptions are logged and reported to the CEO monthly
No exception may be approved by the same individual making the request.
8. Segregation of Duties
The following segregation of duties controls are maintained to prevent conflicts of interest and unauthorized transactions:
- Initiator ≠ Approver: The person requesting a financial transaction may not also approve it
- Payment initiation ≠ Payment authorization: Bank transfers are initiated by the CFO and authorized by the CEO for amounts > $10,000
- Vendor selection ≠ Contract execution: Technical vendor selection (CTO) is separate from contract execution (CEO)
- System access requests ≠ Access grant: Engineers request access; CTO (or CEO for elevated rights) grants it
- No single-person JPMC transactions: All actions taken in connection with JPMC client engagements involving financial commitments require both CTO (technical) and CEO (commercial) awareness
9. Governance and Re-approval
- This document is reviewed and re-approved annually or when organizational roles change materially
- Any change to authority thresholds requires CEO approval
- All role holders listed in this document must confirm their understanding of their authority levels in writing annually
- A copy of this document is maintained in the legal documentation repository and in the JPMC SCA evidence package
10. Review
This document is reviewed annually by the CEO and CFO and updated to reflect any changes in organizational structure, personnel, or business scale.
11. Related Documents
- Signing Authority Policy
- Anti-Bribery & Anti-Corruption Policy
- Employee Code of Conduct
- Third-Party Risk Management Policy
- Change Management Policy
Synthetic Users, Inc. — 3201 Coolidge Ave, Los Angeles, CA 90066, USA