Last updated: 2024/06/26

CitizenX (https://citizenx.com) is a service provided by The Network State Company AG (henceforth referred to as “The Company”).

1. Scope of Service

   These Terms of Use (henceforth referred to as “The Terms”) govern the use of the Platform known as “CitizenX” (https://citizenx.com/) by the Client.

   This service rendered by The Company is limited to individuals who have reached legal age to act on their own behalf according to the legislation of their country of origin.

2. Definitions

   Unless explicitly specified otherwise, the terms outlined below shall have the following definition:

   1. Service: Service refers to the use of the software owned by The Network State Company AG known as “CitizenX” which enables individuals to apply for Citizenship or Residency in Qualified Countries through specialized Investment Programs, subject to the legislation, requirements, regulations, and procedures in force at the time of the application in the referred jurisdictions.
   2. Service Provider: The Network State Company AG, operating through the platform citizenx.com, along with any of its subcontractors, affiliates, and related entities.
   3. Client: Any eligible individual and/or family unit that uses CitizenX to apply individually or jointly for Citizenship or Residency by investment programs in the Qualified Countries, subject to the legislation, requirements, regulations, and procedures in force at the time of the application in the aforementioned jurisdictions.
   4. Qualified Countries: Refers to nations that allow eligible individuals and/or family units to apply for citizenship or residency through specialized investment programs. These countries can be found in https://citizenx.com/.
   5. Citizenship by Investment (CBI): Legal process through which individuals can acquire citizenship in a country by making a significant financial investment in that nation. CBI programs may vary in terms of investment amount, eligibility criteria, processing time, and the rights granted to investors and their families.
   6. Eligible Individual: The individual or group of individuals that meet the criteria established by the Special Investment Programs set forth by the Qualified Country of their choice.
   7. Direct Business Ownership: Ownership where an individual or entity holds legal or beneficial ownership interest directly in a business entity, typically through shares or equity ownership.
   8. Indirect Business Ownership: Ownership held through intermediary entities, such as holding companies or investment funds, which in turn hold shares or equity in the target business entity, rather than owning the business directly.

3. Services Provided

CitizenX provides a series of tiered services, based on the Client’s needs. These services are listed below:

1. Qualified Countries Database: Comprehensive information about Citizenship or Residency by Investment programs in Qualified Countries. Such information is subject to change at any given time, at the sole discretion of the Government of the Qualified Country. CitizenX is not liable for any inaccuracies in the information. This information includes, but is not limited to, general information about the CBI programs, eligibility criteria, overview of the Qualified Country, processing times, associated costs, and investment options.

2. Program Comparison. CitizenX allows its users to compare Citizenship and Residency by investment programs in different Qualified Countries. Said comparison shall not be construed in any way as legal counseling, recommendation, or advisory from CitizenX to pursue a specific program. It is ultimately Client's responsibility to choose the program that best fits their expectations and financial capabilities.

3. Onboarding & Due Diligence Review. Client must fill out an application for in invitation on citizenx.com. During this process, Client will provide relevant data about the applicants, select a Citizen by Investment program, and provide sufficient data to conduct a due diligence analysis and assess eligibility for the program. CitizenX reserves the right to refuse provision of service to Clients who do not fulfill or comply with the internal Due Diligence Policy.

4. Payment of Fees. Upon approval by CitizenX, the client will be required to make payments for fees, investments, and any other associated costs as outlined during the application process.

   You can fund your investments using BTC, USDC, USDT, or ETH. There are a few important restrictions to note when funding investments with crypto:

   • CitizenX is only able to accept BTC, USDC, USDT, or ETH. If you send any other digital asset (eg, USDT, BNB) and/or send assets on any chains that are not supported by CitizenX your crypto will be lost and CitizenX will not be able to receive or return your funds from/to you. The chains supported by CitizenX are Bitcoin mainnet and Ethereum mainnet.
   • CitizenX will not own or control your crypto.
   • CitizenX does not support withdrawals via crypto.
   • Fees:
     • A processing fee of up to 2.5% will be deducted from your investment amount for settlement, custody, and trading costs associated with your payment in any cryptocurrency.
     • If you do not transfer an additional amount to your funds to cover this fee your funds will be reduced accordingly.
   • Eligibility:

     • There may be additional eligibility requirements set by CitizenX's partner financial institutions. You will be able to read and accept the terms of service before the time of the transaction.

     • There are a a few jurisdictions that we cannot provide our Service if paid in crypto currencies. This means that:

       1. we cannot onboard entities located in these jurisdictions
       2. we cannot onboard entities that have UBOs located in these jurisdictions
       3. we cannot send or receive funds from these jurisdictions.

       This is the current list of countries that we cannot provide services in any of the three scenarios listed above, this list is updated regularly based on changing regulatory and partner requirements.

       • Abkhazia
       • Afghanistan
       • Albania
       • Angola
       • Belarus
       • Bosnia and Herzegovina
       • Burma (Myanmar)
       • Burundi
       • Central African Republic
       • Colombia
       • Cuba
       • Democratic People’s Republic of Korea (North Korea)
       • Democratic Republic of the Congo
       • Ethiopia
       • Eritrea
       • Guinea
       • Guinea-Bissau
       • Haiti
       • Iran
       • Iraq
       • Ivory Coast (Cote D'Ivoire)
       • Kosovo
       • Lebanon
       • Liberia
       • Libya
       • Macedonia
       • Mali
       • Myanmar (Burma)
       • Nagorno-Karabakh
       • Nicaragua
       • Northern Cyprus
       • Pakistan
       • Russia
       • Sahrawi Arab Democratic Republic
       • Somalia
       • Somaliland
       • South Ossetia
       • South Sudan
       • Sudan
       • Syria
       • Serbia
       • Sierra Leone
       • Ukraine (Occupied territories)
       • Venezuela
       • Yemen
       • Zimbabwe

5. Application Submission. CitizenX, directly from the website or using third-party service providers will submit the application to the appropriate Government Agency in the Qualified Country of choice.

6. Client Obligations

   Client unconditionally agrees to:

   1. Obligation to Provide Accurate Information. By accessing and utilizing the Service provided by CitizenX, the Client agrees to comply with all applicable Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations and requirements from CitizenX and the Qualified Country of choice. This includes, but is not limited to, providing accurate, legal, and up-to-date information and documentation to verify the Client’s identity and maintain compliance with relevant laws and regulations. The Company reserves the right to request additional information or documentation from the Client at any time to satisfy AML and KYC obligations. Failure to provide requested information or documentation may result in the suspension or termination of the Client's account or access to the Service provided by the Company.
   2. Obligation to obtain and provide Supporting documents. Client must obtain and provide supporting documents for the application process in accordance with the requirements set forth by the Qualified Country of choice. CitizenX may provide assistance and/or advisory on how to obtain the documents required for the application process, subject to any applicable fees.
   3. Compliance with Regulatory and Legal Requirements. Client is responsible for ensuring compliance with all legal and regulatory requirements of the citizenship by investment program chosen by the Client.
   4. Obligation to Cooperate with Due Diligence Processes. Client must cooperate with any due diligence checks or background investigations conducted as part of the application process. This may involve providing additional information or documentation to verify the source of funds and demonstrate good character.
   5. Payment of Fees & Deposit Investment Funds. The client is responsible for covering all relevant fees associated with the Citizenship by Investment program and the services provided by CitizenX. These fees may include government fees, investment, due diligence, and/or processing fees, agent due diligence fees, as well as any other expenses outlined in each program's terms. Additionally, the client must ensure timely deposit of investment funds as required by the program's terms and conditions.
   6. Compliance with Terms of Use. Client must comply with the Terms of Use of the website and the citizenship by investment program they are applying to. This includes adhering to deadlines, providing accurate information, and respecting the confidentiality of sensitive data.
   7. Notifications of Change. Client must notify CitizenX within 10 business days of any changes to their personal or financial circumstances that may affect their eligibility for the citizenship by investment program.
   8. Obligation to Comply with New Requirements. Client must promptly comply with any new requirements or regulations introduced by CitizenX or the relevant authorities that affect their engagement with the service.
   9. Obligation to sign Powers of Attorney. Client must sign Powers of Attorney as requested by CitizenX, including those for third-party providers located in the Qualified Country, to authorize the necessary actions for the completion of the citizenship or residency by investment process.

7. Due Diligence

   Upon receiving the Application for Invitation, as set forth under section 3.3 of these Terms of Use, CitizenX will conduct a Due Diligence Analysis. This analysis may require that the Client provides at least the following documentation:

   1. Financial Information
   2. Proof of funds: Bank statements, investment portfolio details, or other evidence of financial capacity to meet program requirements.
   3. Source of funds: Details on the origin of the invested funds to ensure compliance with Anti-Money Laundering (AML) regulations.
   4. Reference letter from Banks
   5. Employment and Income Details
   6. Reference Letters
   7. Pay slips
   8. Tax Returns
   9. Business Interests
   10. Details of any direct or indirect business ownership or directorships
   11. Financial statements or business registration documents
   12. Background Information
   13. Criminal Record Check from the countries where Client has resided in the last 5 years.
   14. Disclosing previous or current citizenships
   15. CitizenX reserves the right to request additional documents beyond those listed, at its discretion, until it is satisfied that the Client meets the due diligence policy requirements to engage with CitizenX. CitizenX shall not be held liable for any delays in the processing of the application due to missing or incomplete documentation provided by the client.

8. Limitation of Liability

   No Guarantee of Citizenship.

   CitizenX is a secure and private platform through which the Company strives to provide accurate guidance, assessment of eligibility, and support in Citizenship by investment processes. However, by utilizing the Service you acknowledge and agree that citizenship by investment approval is subject to various factors, including but not limited to your eligibility, compliance with citizenship by investment laws and regulations, and above all the discretion of the respective government agencies of Qualified Country, on which the final decision regarding citizenship by investment approval rests solely. Therefore, while the Company will perform its services diligently and competently, factors beyond its control may impact the final outcome, and therefore, CitizenX cannot guarantee the approval of any citizenship by investment application or the attainment of citizenship by investment in any specific country.

   The company's obligation is one of means, not results, meaning that the company is committed to making reasonable efforts to achieve the desired outcome but cannot guarantee specific results.

   Investment Risks.

   The Company shall not be held liable for any losses, damages, or consequences arising from the outcome of Client's citizenship by investment application, including but not limited to investment loss, application denials, delays, or changes in citizenship by investment policies. Client assumes full responsibility for the decisions and actions taken based on utilizing the Service and the information obtained. Furthermore, Client agrees that any testimonials or success stories related to citizenship by investment applications related to the Service are not guarantees of future results and are presented for illustrative purposes only.

9. Delays, Processing Times & Changes in Eligibility Criteria

10. CitizenX commits to exercising diligence in processing and obtaining required documents for the Special Investment Program. CitizenX shall not be held liable for any delays, as timelines are subject to the processing times of Government Agencies and Private Entities. CitizenX shall not be held liable for any delays due to changes in eligibility criteria by the Government from the Qualified Country of Choice.

11. By using this Service, Client agrees to hold the Company harmless from any claims, liabilities, or disputes arising from the citizenship by investment application process. This provision shall survive the termination of this Agreement.

12. Right of Withdrawal

    1. Cancellation of Service. The Client retains the right to cancel the service at any time, provided that a. the legislation and regulations of the Qualified Country of Choice allow it, and/or b. the process is at a stage at which withdrawal is still feasible.
    2. Request for Cancellation. CitizenX shall respond to the withdrawal request within 15 business days, providing details on the possibility of withdrawal in accordance with the regulations of the Qualified Country of Choice, the current stage of the process, and the effects of cancellation.
    3. Refund of Fees for Service, Government Fees & Investment Deposit. The refund of funds received by CitizenX from Client are subject to the terms and conditions outlined in Section 11.

13. Fees for Service, Government Fees & Investment.

    1. Outstanding Fees. Upon receiving the invitation, Client must pay Citizen X's fees, Government Fees and Deposit the required Investment Amount, and other associated costs as outlined during the application process. Client will receive detailed instructions on how to pay the fees.
    2. Refund of CitizenX’s Fees. Citizen X's fees are non-refundable except in the event of service cancellation within 48 hours of payment. Any transfer fees and costs incurred prior to the refund request will be deducted. Refunds must be requested through the client's account on CitizenX.
    3. Refund of Administrative Fees. Administrative fees are only refundable if they have not already been remitted to the respective government agency. Any transfer fees and costs incurred prior to the refund request will be deducted.
    4. Investment Deposit Refund. Investment refunds are contingent upon whether the deposit has already been submitted to the program established by the Government of the Qualified Country of Choice. In such cases, refunds are subject to the rules and regulations governing that program. CitizenX shall not be held liable if refunds of these funds are not feasible. If the deposit has not been transferred to the program, the client shall receive the funds within the timeframe specified by the bank. Transfer fees and any other associated costs incurred in the refund process shall be deducted from the refunded amount.

14. Authorization to Share Data with Third Parties

15. Intellectual Property

16. Miscellaneous Provisions

17. Confidentiality

18. Integrity and Anticorruption Clause