Terms of Service

Effective 2024/06/26

Last updated: 2025/05/21

THE NETWORK STATE COMPANY AG is a Swiss company registered in Switzerland under the number CHE-385.997.597, with registered office at Bahnhofstrasse 20 Zug 6300 Switzerland ("Company" or "CitizenX").

The Company has developed a software platform to help clients acquire residency and/or citizenship in countries welcoming investors and entrepreneurs through regulated investment migration programs ("Business"), as seen in the Company’s website: https://citizenx.com/ ("Web Site").

Please read the following Terms of Service (“Terms”) carefully, as they are binding and, together with other contracts or agreements signed with CitizenX, govern the use of the Web Site and any other services provided within the scope of the Business. By signing these Terms, creating an account, accessing the Web Site or making use of any other services within the scope of the Business, you agree to these Terms.

Please be advised that the Terms may be updated or subject to change at any time and without any prior notice to (i) reflect changes to the Web Site and/or any other services provided within the scope of the Business; (ii) include new services, features, technologies, offers, etc; and/or (iii) adapt to new legal or regulatory developments, etc.

The Terms will be modified in writing and the modifications will come into effect on the last updated date shown above. Please check the Terms frequently for modifications. By renewing or continuing access to the Web Site or continuing use of any other services within the scope of the Business, you agree to the modifications.

1. Definitions:

  • Service”: Service refers to the use of the software owned by 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.
  • Service Provider”: CitizenX, operating through the Web Site and in any other services provided within the scope of the Business, along with the Company’s contractors, affiliates, related entities, etc
  • Client”: Any eligible individual (including their family) that uses CitizenX to apply 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 those jurisdictions.
  • Qualified Countries”: All jurisdictions (whether they be nation states or not, according to applicable international law) that allow eligible persons (and, as the case may be, their family) to apply for citizenship or residency through specialized investment programs. These Qualified Countries can be found in the Web Site (https://citizenx.com/).
  • Citizenship by Investment” or “CBI”: Legal process through which individuals (and, as the case may be, their family) can acquire citizenship by making a significant financial investment in a given jurisdiction. CBI programs may vary in terms of investment amount, eligibility criteria, processing time, and the rights granted to investors and their families.
  • Ultimate Beneficial Owner” or “UBO”: the natural person that is the ultimate beneficiary (holding a minimum of 10% of capital or voting rights in the underlying entity) when a company, institution or entity initiates a transaction.

2. Scope of Service

The Terms govern the provision of the Service, the use of the Web Site and any other services provided within the scope of the Business.

3. Eligibility

The services provided by CitizenX are limited to individuals (natural persons), or their representatives, who have reached legal age to act and legally bind themselves according to the applicable law. The Company has a discretionary right to reject any person or persons who do not comply with the necessary requirements.

4. Other eligibility requirements

There may be additional eligibility requirements set by CitizenX’s partner financial institutions. Client will be able to read and accept the partner’s terms of service before any transaction.

5. Service specifics

Among other services provided within the scope of the Business, CitizenX agrees to provide the following services, all tailored to each Client’s interests, preferences and needs:

  • Qualified Countries database: Comprehensive information about CBI programs in Qualified Countries. Such information is subject to change at any time and with no prior notice, at the sole discretion of the competent government authorities of a given 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.
  • Program comparison: CitizenX offers users the possibility to compare CBI programs in different Qualified Countries. Said comparison shall not be construed in any way as legal counselling, recommendation, or advice 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. -** Onboarding & due diligence review**: Client must commence the onboarding process by filling out an application form. During this process, Client will provide relevant data about the applicant or applicants (family members), select a CBI program, and provide sufficient data for the Company to conduct a due diligence analysis and assess Client’s eligibility for the program. CitizenX has a discretionary right to reject any Client who does not comply with the necessary requirements. In addition, the Company reserves the right to refuse provision of service to Clients who do not comply with internal due diligence policies.
  • Application Submission: CitizenX, directly or using third-party service providers will submit the application to the appropriate government authority in the Qualified Country of choice.

6. Payments

Upon Client approval by CitizenX, Client will be required to make payments for fees, investments, and any other associated costs as outlined during the application process. The Company allows Client to fund fees, investments, and other costs using BTC, USDC, USDT, or ETH. There are 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 asset (i.e. USDT, BNB) and/or send assets on any chains that are not supported by the Company, your crypto will be lost and CitizenX will not be able to receive or return your funds from/to you. The only chains supported and, thus, accepted by the Company are Bitcoin main net and Ethereum main net.
  • CitizenX will not own or control your crypto.
  • CitizenX does not support withdrawals via crypto.
  • CitizenX will deduct a processing fee of up to 5% of your total investment from said investment 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.

7. Restricted jurisdictions

CitizenX will not provide any services in, nor receive funds from the following jurisdictions:

  • 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
  • Kosovo
  • Lebanon
  • Liberia
  • Libya
  • Macedonia
  • Mali
  • 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

This list may be subject to change depending on regulatory and partner requirements. For the avoidance of doubt, CitizenX will not onboard persons or entities located in these jurisdictions. In addition, the Company will not onboard entities that have a UBO located in one of these jurisdictions. Moreoever, CitizenX will not send or receive funds from these jurisdictions.

8. Client’s obligations

Client expressly and unconditionally agrees to:

  • provide accurate information. By accessing and using the Service, Client agrees to comply with all applicable Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations and requirements set forth by both CitizenX, its partners and contractors and by the Qualified Country of choice. This includes, but is not limited to, providing accurate and up-to-date information and documentation to verify the Client’s identity and maintain compliance with relevant laws and regulations. The Company may 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 agreement or relationship with CitizenX, including access to the Service and all other services provided within the scope of the Business.
  • provide supporting documents. Client shall 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 advice on how to obtain the documents required for the application process, subject to any applicable fees.
  • comply with all legal and regulatory requirements. Client is responsible for ensuring compliance with all applicable legal and regulatory requirements.
  • cooperate during the due diligence process. Client agrees to cooperate fully and to the best of their ability with any due diligence checks or background investigations conducted as part of the application process. This may involve providing additional information or documentation (for example, to verify the source of funds or demonstrate good character).
  • pay all fees and make all deposits. The client is responsible for covering all relevant fees associated with the CBI program and the services provided by CitizenX. These fees may include government fees, investments, due diligence fees, processing fees, agent 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.
  • notify all relevant changes. Client shall notify CitizenX within ten (10) business days of any changes to their personal or financial circumstances that may affect their eligibility for the CBI program.
  • comply with any new requirements. Client will comply with any new requirements or regulations set forth by both CitizenX, its partners and contractors and by the Qualified Country of choice.
  • sign all necessary powers of attorney. Client agrees to sign all the necessary powers of attorney as requested by CitizenX, including those for third-party providers.

9. Fees & investment refunds

Client will receive detailed instructions on the payment of all fees and expenses. Such fees will include CitizenX’s fees and may include government fees, investments, due diligence fees, processing fees, agent fees, as well as any other expenses outlined in each program's terms. Citizen X's fees are non-refundable.

10. Due Diligence

To conduct the due diligence process, CitizenX will require from Client, at least, the following documents:

  • Proof of funds (bank statements, investment portfolio details or other evidence of financial capacity to meet program requirements).
  • Source of funds (details on the origin of the funds to be invested to ensure compliance with AML regulations).
  • Employment and income details
  • Reference letters.
  • Pay slips
  • Tax Returns
  • Business Interests
  • Details of any direct or indirect business ownership or directorships
  • Financial statements or business registration documents
  • Background Information
  • Criminal record (e.g. from jurisdictions where Client has resided in the last 5 years).
  • Previous and/or or current citizenships or residencies. CitizenX reserves the right to request additional documentation or information, at its discretion and until the Company is satisfied that all the necessary requirements to become CitizenX’s client have been met. CitizenX is exempt from any liability for any delays in the processing of the application caused by missing or incomplete documentation or information.

11. No guarantee of citizenship or residency

Client acknowledges and agrees that CBI approval is subject to various factors, including but not limited to Client’s eligibility, compliance with CBI laws and regulations and –above all– the absolute discretion of the competent government authorities. Therefore, CitizenX cannot and does not guarantee the approval of any application or the attainment of citizenship or residency by investment.

12. Reasonable efforts

CitizenX undertakes only to deploy its reasonable efforts to ensure Client obtains the selected residency and/or citizenship in the Qualified Country of choice.

13. Investment risks

Client may be required to invest, engage or trade in investment vehicles, assets, products, or services in order to qualify for a CBI program. Such investments may, even if made in accordance with a recommendation, result in losses as well as profits. CitizenX does guarantee any future performance of any such investment made by Client. Client acknowledges that trading in leveraged products (such as but not limited to, foreign exchange, derivatives, commodities, etc.) can be very speculative, and losses and profits may fluctuate both violently and rapidly. 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 in relation to the Service and to all services provided within the scope of the Business. Furthermore, Client agrees that any testimonials or success stories related to CBI applications are not guarantees of future results and are presented for illustrative purposes only.

14. CitizenX is not Client’s advisor

CitizenX does not provide investment, financial or tax advice, including in connection with the Service or with any other services provided within the scope of the Business. Client agrees not to rely upon any statement or content issued by the Company or published on the Web Site, or that is otherwise attributed to CitizenX, as a financial or investment recommendation, advice, or guidance. Client also acknowledges that the Company is not acting as Client’s bank, broker, intermediary, agent, advisor, or as its fiduciary in any capacity, including with respect to the Service or with any other services provided within the scope of the Business.

15. Delays and processing times

CitizenX cannot and will not be held liable for any delays in the application procedure of the CBI program. Only the competent government authorities of the Qualified Country of choice are responsible for any delays and processing times.

16. Changes in eligibility criteria

CitizenX cannot and will not be held liable for any damages or losses suffered by Client as a result in changes to the eligibility criteria by the competent authorities of the Qualified Country of choice.

17. Termination by Client

Client has the right to terminate the agreement with CitizenX at any time, provided that (i) the applicable laws and regulations of the Qualified Country of Choice allow it, and (ii) the process is at a stage at which withdrawal is still feasible. If these two criteria –(i) and (ii)– are not cumulatively met, Client agrees to honor the agreement in full. To request termination of the agreement subject to the aforementioned requirements, Client will have to send a written message via email or by any other secure and viable channel. CitizenX shall respond to the termination request within fifteen (15) business days of its receipt, providing details on the possibility of termination. If termination is possible and still in Client’s interest, termination will take effect fifteen (15) days after CitizenX’s response detailing the possibility of termination. Even in case of termination, Client shall pay all fees, costs and other expenses incurred up to the moment of termination. Client is reminded that CitizenX’s are not refundable, even in the event of termination.

18. Authorization to share data with third parties

Client acknowledges and agrees that, as part of the necessary activities to provide the Service or any other services provided within the scope of the Business, CitizenX may share the information and documentation provided by Client with contractors, government authorities or other third-parties. Therefore, Client consents to the collection, use and disclosure of their personal data for the purposes described herein. CitizenX has established agreements with its providers to protect data privacy in accordance with Swiss laws and the European Regulations of GDPR.

19. Confidentiality

CitizenX agrees to maintain strict confidentiality regarding all information obtained or exchanged when providing the Service or any other services provided within the scope of the Business. Said information shall be used solely to provide the Service or any other services within the scope of the Business.

20. Intellectual property

All content on the Web Site and in any document or publication contained therein (including but not limited to text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software) is and will remain CitizenX’s exclusive property and is protected by copyright, trademark (whether registered or unregistered), design rights, database rights and all other intellectual property rights afforded to CitizenX. All other content related to the Service, the Website or to any other services provided within the scope of the Business is used with permission. Client may not distribute, modify, transmit, reuse, download, repost, copy, or use any of this content, whether in whole or in part, for commercial purposes or for personal gain, without express advance written permission from CitizenX.

21. Other Web Site content

Persons, companies or entities not belonging to CitizenX may advertise or publish their content on the Web Site, through publications, posts, links, banners, etc. The Company is not responsible or liable for the offerings, information, opinions, suggestions, recommendations, etc. of any such third parties. If a visitor of CitizenX’s Web Site decides to act upon any such advertising, such user does so entirely at their own risk. In addition, CitizenX is not responsible for and does not control, endorse or make its own the services, information, data, files, products and any kind of material on the linked or referred sites of the Web Site that belong to third parties. The quality and reliability of the linked or referred sites may vary depending on whether they are updated or altered, so Client should exercise caution when using the services, information, data, files, products and any kind of third-party material on the linked sites. Access to any other site linked to the Web Site is the responsibility of each Client.

22. Force majeure

CitizenX shall not be held responsible or liable for any error, delay, loss, or damage arising from any event beyond the Company’s reasonable control (including, but not limited to earthquakes, floods, extraordinary weather conditions or other acts of God, fires, wars, insurrections, riots, strikes or other labor disputes, accidents, actions of governments, communication or power failures, equipment or software malfunctions, etc).

23. Indemnity

Client expressly agrees to indemnify and hold CitizenX harmless from any losses, damages, liabilities, or expenses (including attorney’s fees) arising out of or in connection with any third-party claims related to the breach of the Terms or any negligent or wrongful acts or omissions on Client’s part in relation to the Terms.

24. Severability

If any provision of the Terms is held invalid or unenforceable, the remaining provisions shall continue to be valid and enforceable to the fullest extent permitted by law.

25. Assignment

Client cannot assign or transfer any right or obligation under the Terms without CitizenX’s prior written consent. On the other hand, CitizenX can assign or transfer any right or obligation under the Terms, in whole or in part, without Client’s consent, subject to compliance with applicable laws. In addition, if the Company is acquired by or merged with a third-party, CitizenX reserves the right to transfer or assign Client’s information as a necessary component of such merger, acquisition, sale, or other change of control.

26. No waiver

The failure of CitizenX to enforce any provision of the Terms (or any other right derived from them) shall not be construed as a waiver of such provision or as a waiver of the right to enforce it.

27. No partnership

Nothing in the Terms will be deemed to or is intended to be deemed to, nor will it, cause Client and CitizenX to be treated as partners, joint venturers, or otherwise as joint associates for profit.

28. Privacy Policy

CitizenX’s privacy policy is available at the following link (https://citizenx.com/privacy-policy) and is hereby incorporated into these Terms.

29. Governing law and dispute resolution

The Terms shall be governed by and construed in accordance with the laws of England and Wales. All disputes arising out of or in connection with this Engagement Letter shall be finally settled under the Rules of Arbitration of the International Chamber of Commerce by one arbitrator appointed in accordance with said Rules. The arbitration proceedings shall be conducted in English and the Seat of the proceedings will be Zurich. The Emergency Arbitrator provisions shall not apply. The Expedited Procedure Provisions shall not apply.