Integrity and Prevention of Illicit Use Policy

Last updated: September 20, 2026.

BitSur LLC promotes a culture of legality, transparency, security, and responsible use of technology. This Policy establishes principles applicable to BitSur’s website, training programs, consulting services, and business relationships.

Essential scope: BitSur provides technology education and consulting. It does not receive, transmit, custody, manage, or invest third-party funds or cryptoassets; operate an exchange, payment platform, or digital-asset purchase or sale service. Accordingly, this Policy must not be interpreted as a statement that BitSur provides regulated financial services or acts as an obligated institution in jurisdictions where it is not one.

1. Objectives

prevent BitSur’s website, brand, content, or services from being used for fraud, money laundering, terrorist financing, corruption, sanctions evasion, cybercrime, or other unlawful activities;
protect participants, clients, suppliers, personnel, and third parties;
maintain transparent and documented business relationships;
respond proportionately to risk indicators and valid legal requests.

2. Principles of Conduct

BitSur and its collaborators will act with honesty, documentary traceability, confidentiality, respect for the law, and prevention of conflicts of interest. Instructions intended to conceal identity, source of funds, beneficiaries, the purpose of an engagement, or the nature of an activity will not be accepted.

3. Prohibited Activities

BitSur’s services, materials, communications, or brand may not be used for:

fraud, impersonation, phishing, malware, or credential theft;
money laundering, terrorist financing, or weapons proliferation financing;
evasion of applicable economic sanctions or legal restrictions;
corruption, bribery, extortion, or document manipulation;
pyramid schemes, misleading promises of returns, or unauthorized solicitation of funds;
infringement of third-party intellectual property, privacy, or security;
requesting BitSur to custody assets, receive transfers to purchase cryptoassets, execute transactions, or manage investments.

4. Reasonable Knowledge of Counterparties

For open training programs, contact and registration information will generally be sufficient. For business services or higher-risk relationships, BitSur may request reasonable information concerning identity, authority to act, business activity, beneficial ownership, the purpose of the service, and the lawful source of contractual payments.

The depth of review will be proportionate to the nature, jurisdiction, complexity, and risk indicators of the relationship. Requesting information does not mean that BitSur is a financial institution or monitors digital-asset transactions.

5. Payments for BitSur Services

BitSur accepts only payments corresponding to legitimately contracted training, consulting, or technology deliverables. Commercial documents must identify the service and counterparty. BitSur may reject unrelated third-party payments, payments inconsistent with an invoice, or unusual structures lacking a reasonable explanation.

BitSur does not receive money for the purpose of converting, transferring, or delivering it as cryptoassets to another person.

6. Sanctions and Restricted Jurisdictions

BitSur seeks not to maintain relationships prohibited by sanctions or restrictions applicable in the United States. When warranted by the nature of an engagement, it may compare information against official lists and request additional clarification. No person has an automatic right to engage BitSur.

7. Red Flags

Without constituting an exhaustive list, the following may result in review or rejection:

false, inconsistent, or unverifiable information;
unjustified refusal to identify the counterparty or beneficial owner;
requests to alter descriptions, invoices, or recipients;
pressure to use third-party accounts or split payments without a business reason;
unauthorized use of the BitSur brand to offer investments, purchase or sale, or custody services;
requests to teach techniques intended to circumvent controls, conceal funds, or evade legal obligations;
reasonable links to fraud, corruption, sanctions, or technology-related crimes.

8. Response Measures

Depending on the circumstances, BitSur may request additional information, suspend a conversation, reject or terminate a relationship, preserve records, block misuse of its materials, consult professional advisers, or respond to requests from competent authorities. Any communication to authorities will be made when legally required or advisable under applicable law.

9. Data Protection and Confidentiality

Information obtained to evaluate a relationship will be handled in accordance with the Privacy Policy, with limited access and proportionate retention. BitSur may disclose information where there is authorization, a legal obligation, a valid order, or a legitimate need to protect rights and safety.

10. Training and Internal Review

BitSur will seek to ensure that individuals involved in sales, support, contracting, and service delivery understand this Policy, relevant red flags, and escalation channels. The Policy will be reviewed when services, risks, or relevant legal requirements change.

11. Misuse of the Brand

No person is authorized to represent themselves as a BitSur agent for the purpose of receiving funds, selling cryptoassets, managing investments, or guaranteeing returns. Any such offer must be considered unauthorized and reported immediately.

12. Reports and Contact

Suspected fraud, impersonation, or illicit use of the brand may be reported to compliance@bitsur.us. BitSur will evaluate reports in good faith and may request additional documentation.

13. Amendments

BitSur may update this Policy to reflect changes in its services, risks, or applicable law. The current version will be the version published on the website.

This Policy expresses internal integrity and prevention standards. It does not constitute a certification, financial license, or declaration of voluntary submission to a regulatory regime that is not legally applicable.