Scope

The Company’s role is limited to compliance oversight and operational services. No community funds are deposited into Company-controlled bank accounts.

This policy applies to:

• All DAO participants, promoters, referral partners, and service providers.
• All phases of TBC token distribution.
• All payments made in fiat, stablecoins, or cryptocurrencies.
• All cross-border transfers between Wyoming, Dubai, and other jurisdictions.

Principles

The Company’s role is limited to compliance oversight and operational services. No community funds are deposited into Company-controlled bank accounts.

Trust Bitcoin is committed to:

1. Compliance with law — Align with U.S. FinCEN guidance, UAE VARA/DMCC rules, and FATF recommendations.

2. Risk-based approach — Apply stricter controls to higher-risk participants and jurisdictions.

3. Transparency — 100% on-chain token distribution through audited smart contracts.

4. Community protection — Safeguard members from fraud, market abuse, and illicit use of tokens.

Customer Due Diligence (CDD)

Before participating, users must provide:

• Full Legal Name
• Residential Address
• Email & Wallet Address
• Government-issued Photo ID (passport, national ID, driver’s license)
• Proof of Address (utility bill, bank statement, within last 90 days)

CDD is mandatory for:

• New token purchasers (primary sales)
• Members placing Sale Bids above thresholds
• Participants receiving tourism rewards

Enhanced Due Diligence (EDD)

EDD is applied where:

• Transaction value exceeds USD 10,000 equivalent
• Participant is from a high-risk country (per FATF list)
• Source of funds appears unusual or inconsistent

EDD requires:

• Declaration of Source of Funds
• Bank/Exchange statements or supporting documents
• Additional verification calls or video KYC

Sanctions & Prohibited Users

We prohibit access by individuals or entities:

• Listed on OFAC, UN, EU, or UAE sanctions lists
• Residing in FATF high-risk or blacklisted jurisdictions
• Attempting to use TBC for illegal activities (fraud, darknet markets, etc.)

Ongoing Monitoring

• All transactions are monitored against blockchain analytics tools.
• Suspicious Activity Reports (SAR) may be filed with relevant regulators.
• Periodic re-verification of KYC data (at least every 12 months).

Record Keeping

• All KYC/AML data is retained for minimum 7 years.
• Data is stored securely with restricted access.
• Records may be shared with regulators upon request.

Reporting Obligations

We will promptly report to authorities in:

• Wyoming (U.S. FinCEN guidance)
• Dubai (DMCC / VARA AML obligations)
• Any other jurisdiction where we operate