AML Policy

Our posture

OffshoreGuy, a service operated by Bitcitizen LLC ("Bitcitizen," "we," "us," or "our"), positions itself as a conservative Designated Non-Financial Business or Profession (DNFBP) per FATF Recommendation 22. We apply tier-based KYC, run sanctions screening on every order at every tier, and forward ultimate-beneficial-owner information to regulated licensed local providers who collect their own per-jurisdiction obligations.

Sanctions screening

Every order is screened against OFAC SDN, EU consolidated sanctions, and UN sanctions lists. Name, date of birth, and country are submitted to our sanctions-screening provider for adverse-media and PEP screening. Flagged orders are halted and routed to manual review.

KYC tier breakdown

Tier 0 (under $1,000): email + country + intent. No government ID collected by OffshoreGuy. Note: the licensed local provider in your chosen jurisdiction may collect UBO information independently per local AML law.

Tier 1 ($1,000 to $10,000): ID + proof of address + source-of-funds attestation via our KYC partner.

Tier 2 (over $10,000 or any licensed-service tier): UBO declaration + source-of-wealth + manual enhanced-due-diligence review.

Local-jurisdiction filing disclosure

Our licensed local providers in offshore jurisdictions are regulated trust-and-corporate-service providers and are statutorily required to identify the UBO. OffshoreGuy collects the minimum information required at the platform tier and passes UBO information directly to the licensed local provider, who completes their own verification. We do not duplicate the verification work and we do not retain documents the licensed local provider does not require.

Record retention

We retain KYC records for five years following account closure, consistent with FATF guidance. Records are stored encrypted at rest with access scoped to the compliance reviewer role.

Reporting

If a customer's pattern of activity is consistent with a Suspicious Activity Report (SAR) trigger under applicable jurisdictional law, the relevant regulated licensed local provider in that jurisdiction is responsible for the SAR filing. OffshoreGuy will cooperate fully and provide documentation.

Not legal or compliance advice

This AML Policy describes OffshoreGuy's own compliance posture and our current understanding of the obligations that apply to us. It is provided for transparency. It is not legal, regulatory, tax, or compliance advice, and reading it does not create an attorney-client relationship.

AML, KYC, beneficial-ownership, and reporting obligations vary by jurisdiction and change over time. You are responsible for the obligations that apply to you. Before you rely on anything in this policy, obtain advice from a qualified attorney licensed in the relevant jurisdiction and, where appropriate, a licensed AML-compliance specialist for your specific situation.

We review and update this policy as our posture and applicable law evolve. The effective date above reflects the most recent revision.