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Canadian Real Estate Opportunities


Now you can participate in a
Lucrative Canadian Real Estate Transaction using Tokens.
Join a team of Seasoned Real Estate Professionals
offering Tokenized Real Estate Opportunities for qualified investors.

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Digital Block Real Estate Tokens

1. Each Token represents one share of stock in the Development Company that owns the real property.
2. Liquidity – Trade Tokens on the Stobox P2P Platform.

Token Sale Process

DBRE Token Sale Process

The principals of DIGITAL BLOCK have a combined total of over 45 years of experience in the building and development industry, during which time they have established a reputation for excellence and integrity and have successfully completed projects in North America, Europe and the Middle East. We employ innovative and state-of-the-art design, engineering and construction techniques that enhance the final finished product.


Cathy Bi – Senior VP – Acquisitions

Cathy Bi holds an MBA degree from Ohio State University.  She is also a registered real estate agent and a registered real estate broker for the last 15+ years.  Prior to becoming a real estate agent & broker, Cathy worked for over 15 years at the Canadian Imperial Bank of Commerce in Toronto, Canada.  Cathy is an accomplished business executive that has completed several major real estate transactions.

George Davis – Advisory Board Member

Mr. George Davis has been in the real estate development & construction industry for over 45 years since moving to Canada from the UK.  Mr. Davis has held several progressive position titles with the most recent being Senior Vice President of Construction for Ellis Don Corporation, a major Canadian Development & Construction company engaged in commercial P3 real estate projects across Canada.

Ali Ruzgar – Consultant – Construction

Ali Ruzgar if the Founder & CEO of Roniso Corporation.
Roniso Corporation is now one of the well recognized companies in the field of construction and renovation in the Province of Ontario. Over the years, our specialists have been trusted for their vast experience in the interior and exterior renovations, combined with our ability to provide quality service on projects ranging from high rise residential and mixed use buildings, commercial and retail buildings, institutional facilities and low rise residential buildings.

Raj Singh – President

Raj Singh is the Founder of the Hazelton Development Corporation.  Mr. Singh has been involved in the development & construction of multi-family real estate projects since 2013.

A senior executive with over 25+ years’ business experience in real estate development, technology and business services related businesses. He has in depth experience developing leading edge business models for the Human Capital Management and Consulting Services industry utilizing innovative technology. He has held several executive positions that include positions as Founder & CEO, President & COO and Business Consultant in various publicly listed (TSX) and private companies.

Responsibilities have included operations management, corporate finance (mergers & acquisitions, raising both debt & equity financing), capital markets activities, operational & financial restructuring, building and managing high performance sales & delivery teams, conceptualizing, developing and executing sales & marketing strategies and technology product development & management.

Raj holds MBA (FIU) & BSc. (York) degrees and has completed post graduate studies in Mergers & Acquisitions at the Wharton School.  He has also published scientific papers the Journal of Biochemistry and the Journal of electrophysiology while an undergraduate.

Aavish Rabbani – VP – Marketing & Sales

Well-versed in marketing & sales, skilled negotiator, and strategist.
Results-proven management professional with more than 12 years of experience in Sales/ Marketing & Customer Service.

Has extensive industry knowledge which ranges from new Condo developments, residential sales, luxury homes, and commercial transactions.

Worked on many pre-construction projects in the GTA & surrounding areas.

Worked as a Site Manager and Director of Sales & Marketing for Maplehurst Homes in Peterborough from 2005-2009.

  • Presently working with CITYSCAPE REAL ESTATE since 2013 as a Realtor.
  • Presently working on a new Housing Development named “CASCADA TOWNS NIAGARA” by Pivotal Communities as one of the Directors and as Sales & Marketing Director.
  • Working with Hazelton Group as their Sales & Marketing Executive.


IBI Group


E-Lumen International Inc

E-Lumen International Inc

Jablonsky AST

Structural Engineers

HGC Engineering

Acoustical Engineers

Maxwell & Associates

Mechanical Engineers

Husson Engineering Mangement Company

Civil Engineers

LEA Consulting

Transportation/Traffic Engineers

Soil Engineers ltd

Environmental & Soil Engineers

Harris Sheaffer LLP


Gillam Urban Constructors Inc.

Construction Managers

Turner & Townsend

Project & Cost Management Consultancy

Planning & Urban Design Consultants

The affiliates listed above are individuals or firms that the management team has retained for work on current or past projects under various other companies. These affiliates may be retained by DBRE or its subsidiaries for future projects.


Current & Past Projects
by DBRE's Team Members

Over the years, DIGITAL BLOCK has worked on a wide-range portfolio of residential, commercial and industrial projects, both independently and as joint venture partners, and we assemble awarding winning consulting teams that bring leading edge design concepts to life.



Burlington Town Homes

Frivick (Custom Home)


For inquires regarding the sale of land, private equity, real estate and financing please contact us.

By submitting this form, you are agreeing to receive communications from The Hazelton Group and acknowledge that you may unsubscribe at any time. We do not share information with third parties.


3000 Steeles Avenue East Suite 204
Markham, ON L3R 8T3

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Privacy Policy

Digital Block Real Estate Developments Limited.
Privacy Policy

Last revised: 30.11.21

Digital Block Real Estate Developments Limited (hereinafter – “Company”, “we’, “us”, “our”) is the data controller for the purpose of the General Data Protection Regulation (EU) 2016/679 (hereinafter – “GDPR”) and the BVI Data Protection Act, 2021. This Privacy Notice together with our Terms of Use sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us for the purposes of provision of our services to you through our website and/or other applicable software, including but not limited to: the Digital Securities Dashboard (hereinafter – the “Dashboard”). The website can be accessed via the following link: (hereinafter – the “Website”).

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Website, you are accepting and consenting to the practices described in this Privacy Notice.

We take the protection of our user’s (“user/you/your”) personal data very seriously and strictly comply with applicable data protection laws and regulations. In this Privacy Notice below we provide you with an overview of what data we collect for what purpose and how we ensure the protection of such data.

1. Purpose and Legal Basis of Processing Data; Legitimate Interests

1.1. Legal basis for collection and processing of your personal data
Applicable legal provisions are in particular those of the regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016, repealing the directive 95/46/EC, on the protection of individuals with regard to the processing of Personal Data, on the free movement of such data (“General Data Protection Regulation”, GDPR). We will only collect, use and/or pass on Personal Data if this is permitted by law or if the user consents to the data processing.

1.2. Your data will be used for the following purposes:
1. to implement this Privacy Notice and carry out the contractual relationships between you and us regarding our services available via the Website and/or our other software, including the DS Dashboard (Art. 6 (1) b. of GDPR);
2. to provide our services on the Website, to contact you in any matters regarding our services (also by means of emails and messaging) and to ensure the technical functionality of our services fulfillment of contractual or pre-contractual obligations (Art. 6 (1) b. of GDPR);
3. to prevent fraudulent behavior by any of our users (Art. 6 (1) b. and f. of GDPR);
4. to analyze your use of our services and improve our services (Art. 6 (1) b. and f. of GDPR);
5. with your express consent or instruction to carry out our business activities or send you newsletters and other advertising materials (Art. 6 Para. (1) a. of GDPR);
6. to follow our internal policies and protect our legitimate interests (Art. 6 (1) a., b. or f. GDPR or Art. 9 (2) a. of GDPR);
7. to save your blockchain data (e.g. your Ethereum wallet address) on the distributed ledger (on Art. 6 (1) f. of GDPR);
8. to comply with our legal obligations before third parties involved in the process of performance of our services (Art. 6 (1) c. GDPR);
9. to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
10. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. You have the right to request us not to process your data for the purposes of direct marketing.
11. to notify you about changes to our services;
12. to ensure that content from our Website is presented in the most effective manner for you and for your device; 
13. for other purposes otherwise explained in this Privacy Notice or by any further communication from us; and
14. to comply with any applicable ‘know your customer’, anti-money laundering, or anti-terrorist financing laws and regulations in any jurisdiction in which we operate, including, without limitation, the British Virgin Islands.

2. Your Consent
We can collect and process your data with your consent. By clicking “I Agree” button on any of our resources or using our Website, or other of our services you confirm that you fully agree with this Privacy Notice and provide explicit and full consent to us for collection, processing and transferring of your personal data, inter alia, outside the British Virgin Islands (including the sharing and disclosure of such personal data in accordance with paragraphs 3 and 7 below).

3. Recipient(s) of Your Data
We, as well as our external service providers, receive your data for the purpose of provision of our services. We may need to share your information with our external service providers, affiliates and/or agents.
We require that third party organizations who handle or obtain personal information as service providers acknowledge its confidentiality and undertake to respect an individual’s right to privacy and comply with data protection principles including this Privacy Notice.

4. Information We May Collect From You

4.1. We may collect and process the following data about you:
1. your name;
2. physical address;
3. e-mail address and phone number;
4. credit card information, Ethereum wallet address, other financial information applicable for provision of our services;
5. date of birth;
6. gender and nationality.

In order to obtain the above-mentioned information we may either ask it from you during your filling of any forms (e.g. registration forms) to access our services. Or, we may ask you to provide us with copies of respective documents by phone, e-mail or otherwise. Such documents include but not limited to:
– passport;
– driver license;
– transaction history;
– certificates.

4.2. Digital Block Real Estate Developments Limited. may also gather data about you:

- When you engage with us on social media;

– When you enter prize draws or competitions;

- When you book any kind of appointment with us or book to attend an event;

- When you choose to complete any surveys we send you;

- When you comment on or review our products and services;

- When you have given a third party permission to share with us the information they hold about you;

– When Digital Block Real Estate Developments Limited. suppliers and partners share information with us.

4.3. We may collect your data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law in relation towards KYC and AML regulation.

4.4. We may collect notes from our conversations with you, details of any complaints or comments you make, details of investments you made and how and when you contact us.

4.5. With regard to each of your visits to our Website we may automatically collect the following information:
1. technical information, including the internet protocol (IP) address used to connect your computer to the internet;
2. browser type and version;
3. time zone setting;
4. browser plug-in types and versions;
5. operating system and platform.
6. information about your visit, including the full uniform resource locators (URL) clickstream to, through and from our Website (including date and time);
7. products you viewed or searched for;
8. page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
9. methods used to browse away from the page and any phone number used to call our customer service number.

4.6. Information we receive from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

5. Your Rights

5.1. You have the right to:
1. withdraw your consent relating to the use of your data any time with effect for the future when such data processing is based on your consent*;
2. object to the processing of your personal data, if your personal data is processed on the basis of legitimate interests (based on Art. 6 (1) f. GDPR);
3. access the scope of data stored by us;
4. amend or rectify your data if such data is incorrect or outdated;
5. request the restriction of processing of your personal data;
6. request the erasure of your data**;
7. receive information about the stored data (in a structured, current and machine-readable format) at any time;
8. be informed (subject to applicable statutory limitations) of whether your personal data is being processed by us or on our behalf and, if so, be informed of a description of:
(a) the personal data relating to you which is being or will be processed;
(b) the purposes for which the personal data is being or will be processed;
(c) the recipients or classes of recipients to whom personal data is or may be disclosed; and
(d) any information available to us as to the source of the data.
* Please note that if you become our Investor as described in the Dashboard Terms of Use (link) and at any point will decide not to use our services and/or products we are legally obliged to nevertheless store your data related to you as our investor for the purposes of maintenance of our Investor list.
** Please note, that your blockchain data stored on a distributed ledger is pseudonymized and in any case cannot be deleted by us due to the consequences for the integrity of the entire chain, specifically, due to deletion of such chain containing transactions validation history of other users.

5.2. To enforce your above mentioned rights, you may reach us through the email address included at the end of this document.

6. Period for Storing Your Data;

Deletion of Your Data
The data that we collect from you will be stored and processed for the period of time necessary to provide you our services and will be deleted, subject to any retention requirements contained in any applicable law, after there will be no need in its storage and processing. Please note that when using our Website and/or any of our available services certain information and data about the user will be stored on the blockchain in pseudonymized form and may not be deleted.

7. Disclosure of Your Data

7.1. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries as well as the above-mentioned third party services providers. We provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify in our contract with them. We work closely with them to ensure that your privacy is respected and protected at all times. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

7.2. We may share your data with selected third parties including:
– business partners, suppliers and subcontractors for the performance of any contract we enter into with them to render you our services;
– advertisers and advertising networks that require the data to select and serve relevant adverts to you;
– analytics and search engine providers that assist us in the improvement and optimization of our Website;
– credit reference agencies for the purpose of assessing your credit score where this is a condition for us entering into any agreement with you regarding our services;
– in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
– if we or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
– if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements between you and us, or to protect our or our customer’s rights, property, or safety. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
– we may, from time to time, expand, reduce or sell the Company and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

8. Use of the Blockchain
When using our services, including Dashboard, certain information and data about the user will be stored on the blockchain in pseudonymized form and may not be deleted because it is not possible without deleting the entire chain.
Such data stored on the blockchain will only be in pseudonymized form, including address (public key) of the user of the relevant services, a flag that the user is verified, a flag stating that the user is a sophisticated investor, a flag that the user has verified their bank account. In this event and if such data is considered to be a Personal Data, the data processing by us is subject to Art. 6 (1) f. of GDPR based on our legitimate interest in using and providing this technology for our services in a functioning way.

9. Sharing Your Data With Authorities

We will only do this in very specific circumstances, for example:
– for fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

- we may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

10. Cookies

10.1. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree to accept them. Cookies contain information that is transferred to your device’s hard drive. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse the Website you consent to our use of cookies.

10.2. We use the following cookies:
– strictly necessary cookies – which are required for the operation of our Website, including, cookies that enable you to log into secure areas of our Website;
– analytical/performance cookies – which allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for in the possible easiest way;
– functionality cookies – which are used to recognize you when you return to our Website, enabling us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region);
– targeting cookies – which record your visit to our Website, the pages you have visited and the links you have followed. We use this information to make our Website more relevant to your interests. We may also share this information with third parties for this purpose.

10.3. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

10.4. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

11. Access to Information on Your Data

11.1. GDPR and the BVI Data Protection Act, 2021 give you the right to information held about you and information can be accessed in accordance with GDPR and the BVI Data Protection Act, 2021 by emailing …..

12. Changes to Our Privacy Notice

12.1. Any changes we may make to our Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Notice.

13. Contacts

13.1. Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to Bhaktraj Singh via email [email protected].

Terms of Use

Digital Block Real Estate Developments Limited.
Terms of Use

Last revised: 30.11.21

These Digital Block Real Estate Developments Limited. Dashboard Terms of Use (hereinafter – the “Terms of Use” or “Digital Block Real Estate Developments Terms”) apply to and govern your permitted users’ access to and use of the Ethereum based application (the “Digital Block Real Estate Developments Dashboard” or “Dashboard”) and the services and tools made available on the Dashboard (collectively, the “Services”).
These Terms form the agreement between Digital Block Real Estate Developments Limited. (“Digital Block Real Estate Developments”, “we”, “us”, “our”) and you as a physical person or the legal entity which you represent (“you” or “your”), and constitute a binding legal agreement. ‍
Please read these Terms of Use carefully, as they govern your use of our Services, and expressly cover your rights and obligations, and our disclaimers and limitations of legal liability, relating to such use. By clicking “I Agree” to the Terms of Use or using the Services, you accept and agree to be bound by and to comply with these Terms of Use. If you do not agree to these Terms of Use, you must not access or use our Services.

For the purpose of clarity and understanding, the terms listed below shall have the following meaning:

– a user account assigned to you after completion of the registration procedure on the Digital Block Real Estate Developments web-site available via the link

means, with respect to a party to these Terms of Use, any legal entity that, directly or indirectly controls, is controlled by, or is under common control with such party.

“Applicable Law”
has the meaning set out in Section 12.

means the Ethereum Blockchain utility token that may be used to purchase computational resources to run decentralized applications or perform actions on the Ethereum Blockchain.

“Ethereum Blockchain”
means the underlying blockchain infrastructure which Digital Block Real Estate Developments utilizes to provide its Services.

“Governmental Authority”
includes any domestic or foreign federal, provincial or state, municipal, local or other governmental, regulatory, judicial or administrative authority.

– a user who has a registered Account, has access to the Dashboard and utilizes the Services to purchase a portion of Digital Block Real Estate Developments tokens.

– a user who has a registered Account, has access to the Dashboard and utilizes tools provided to him to operate his own version of the Dashboard, offer for purchase his own tokens and enjoy other services provided by us in this regard as described further in Section 3 “DIGITAL BLOCK REAL ESTATE DEVELOPMENTS DASHBOARD SERVICES, FEES”.

has the meaning set out in article 3.1 below.

– a security token which is a form of Digital Block Real Estate Developments digital non-voting shares, which can be purchased by the Investors via Dashboard (the terms of which are more fully set out in Prospectus).

“Usage Fees”
has the meaning set out in article 3.3 below.

We reserve the right, in our sole discretion, to modify Digital Block Real Estate Developments Terms From time to time. Any and all such modifications are effective immediately upon posting. By clicking “I Agree” to any modified terms or by continuing to access or use the Services, you accept and agree to be bound to the modified terms. You agree to frequently review the Digital Block Real Estate Developments Terms to ensure that you are aware of any such modified terms.


Services for Issuers – provision of access to a set of instruments that allows you to configure and run your own web-based digital securities management platform –Dashboard. The mentioned Services consist of the following actions and items (but not limited to them):

3.1.1 tools to access your account which we will provide to you on the Digital Block Real Estate Developments platform;

3.1.2 tools to operate your registered account and digital securities management platform;

3.1.3 tools to run the Dashboard where users can enjoy tokenized securities purchase services provided and regulated by you;

3.1.4 tools to purchase and utilize DBRE to gain access to the Services on our platforms, including the Dashboard;

3.1.5 tools to manage your tokenized securities transfers, including allowance/ban of transfer to all or part of your investors, to burn your tokenized securities and other options;

3.1.6 access to an interface to whitelist and/or blacklist and otherwise manage your potential and existing investors and other interfaces or tools allowing you to manage your digital securities management platform;

3.2 Services for Investors – provision of access to a set of instruments that allows you to purchase and utilize our tokenized securities via the Dashboard. The mentioned Services consist of the following actions and items (but not limited to them):

3.2.1  tools to register your account on the Digital Block Real Estate Developments platform, which can be accessed via the following link;

3.2.2 tools to validate yourself as an investor, including but not limited to completion of our Know Your Customer (“KYC”) procedures;

3.2.3 tools to purchase our DBRE token and enjoy other available services.

3.3 Usage Fees – We may charge fees to you in consideration of your use of certain Services, including, but not limited to, access to the Dashboard. The details of the Usage Fees, including the amount of each Paid Service costs, when Usage Fees apply and how they are calculated can be found here. Digital Block Real Estate Developments reserves the right to change the Usage Fees at any time, and will provide you with a notice of any such fee changes before they become effective.

3.4 Ethereum Gas Charges – Some Services involve the use of the Ethereum Blockchain, which may require you to pay a fee, commonly known as “Ethereum Gas Charges”, for the computational resources required to perform a transaction on the Ethereum Blockchain. You acknowledge and agree that Digital Block Real Estate Developments has no control over: (a) any Ethereum Blockchain transactions; (b) the method of payment of any Ethereum Gas Charges; or (c) any actual payments of Ethereum Gas Charges. Accordingly, you must ensure that you have a sufficient balance of Ether stored at your Ethereum Address to complete any transaction on the Ethereum Blockchain before initiating such Ethereum Blockchain transaction. We will make reasonable efforts to notify you of any Ethereum Gas Charges before initiating any Services that require the use of the Ethereum Blockchain.

3.5 Taxes – The Usage Fees, and any other charges hereunder, can be subject to any applicable sales, value-added, excise, withholding and other taxes. You are solely responsible for paying any such taxes applicable to the consideration payable under these Terms, as may be required under Applicable Law and you agree to indemnify and hold harmless Digital Block Real Estate Developments from any liability for the same.

3.6 Acceptance of payment – notwithstanding the amount of tokens you have indicated in the appropriate line on the Dashboard, we will transfer you tokens only in the amount that you have paid for, meaning that if there is a discrepancy between the amount of tokens that you put in the appropriate line on the Dashboard and the amount of money you have paid, we will transfer you an amount of tokens equal to the amount of received payment.

3.7 Return of payments – Please note, that we will transfer your funds back in the following cases:
– if you have provided payment in the amount which is less than the established minimum cap for token purchase;
– if you have provided payment via any bank, wallet address or other payment instrument which is different from the whitelisted one during the registration procedure;     
– in the event that you fail to complete any KYC procedure required or undertaken by Digital Block Real Estate Developments at any time (including, without limitation, any KYC procedure required or undertaken subsequent to any initial KYC procedure pursuant to which Digital Block Real Estate Developments requires any additional or updated documentation).


4.1 Account – You must have a registered account on our web-site in order to use the Services. During registration, in order to create an Account, we will ask you to provide certain information, including, but not limited to: your name, your physical address, your email address and/or your Ethereum Address.

4.2 Your Responsibilities – As a condition to accessing or using the Services, you shall:

4.2.1 only use the Services for lawful purposes and in accordance with these Terms of Use;
4.2.2 ensure that, at all times, all information that you provide for the Services, including the information in your Account, is complete and accurate;
4.2.3 maintain the security and confidentiality of your Account and Ethereum Address.

4.3 Unacceptable Use or Conduct – As a condition to accessing or using the Services, you will not:

4.3.1 violate any Applicable Law, including, without limitation, any relevant and applicable anti-money laundering and anti-terrorist financing regimes;

4.3.2 infringe on or misappropriate any contract, intellectual property or other third-party rights using the Services;

4.3.3 use the Services in any manner that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying the Services, or that could damage, disable, overburden, or impair the functioning of the Services in any manner;

4.3.4 attempt to circumvent any content filtering techniques or security measures that Digital Block Real Estate Developments employs for the Services, or attempt to access any service or area of the Services that you are not authorized to access;

4.3.5 use any malware or other automated means not provided by us, to access the Services or to extract any data which can be gained utilizing the Services;

4.3.6 use or attempt to use another user’s Account without authorization;

4.3.7 post content or communications using the Services that we, in our sole discretion, consider to be libelous, defamatory, profane, obscene, pornographic, sexually explicit, indecent, lewd, vulgar, suggestive, harassing, hateful, threatening, offensive, discriminatory, bigoted, abusive, inflammatory, fraudulent, deceptive or otherwise objectionable;

4.3.8 use the Services from a jurisdiction that we have, in our sole discretion, or a relevant Governmental Authority has determined is a jurisdiction where the use of the Services is prohibited;

4.3.9 encourage or induce any third party to engage in any of the activities prohibited under this Section 4.3.

4.4 Your Assumption of Risks – You represent and warrant that you:

4.4.1 have the necessary technical expertise and ability to review and evaluate the security, integrity and operation of any tokens, including DBRE, that you decide to interact with;

4.4.2 have the knowledge, experience, understanding, professional advice and information to make your own evaluation of the merits, risks and applicable compliance requirements under Applicable Law of any security token activity you engage in and are able to incur a complete loss of any amounts invested using the Dashboard without impairing your financial condition;

4.4.3 know, understand and accept the risks associated with your Ethereum Address, the Ethereum Blockchain, Ether, DBRE;

4.4.4 accept the risk of purchasing DBRE, exchanging them and otherwise utilizing the Services, and are responsible for conducting your own independent analysis of the risks specific to your use of the Services;

4.4.5 understand and accept that the Services are software applications consisting of code subject to flaws and that you acknowledge that you are solely responsible for evaluating any code provided and for evaluating the functioning of any Services accessed without any liability to Digital Block Real Estate Developments.

4.5 Account Activities – You acknowledge and agree that you will be bound by, and hereby authorize Digital Block Real Estate Developments to accept and rely on any agreements, instructions, orders, authorizations and any other actions made, provided or taken by anyone who has accessed or used your Account, regardless of whether such access is authorized or unauthorized. You further acknowledge and agree that Digital Block Real Estate Developments will not be liable for any of its actions that you have authorized it to take.

Please refer to our Privacy Notice or information about how we collect, use, and share your information.


6.1 Ownership of Services – Excluding any open source software or third-party licensed software that the Services incorporate, Digital Block Real Estate Developments owns the Services, including all technology, content, intellectual property objects and rights in them and other materials used, displayed or provided on or in connection with the Services.

6.2 Licence; Open Source Software Licence; Limitations – The source-code for our Services are governed by the source-code licence available on github repository available via the link and any other applicable licensing terms for the Services mentioned in these Terms. You acknowledge that the Services may use, incorporate or link to certain open-source components and that you will comply with any applicable open-source licences that govern any such open-source components.

6.3 Trademarks – Any of our product or service names, logos, and other marks used in or as a part of the Services, including our name and logo are trademarks owned by Digital Block Real Estate Developments, its Affiliates or its applicable licensors. You may not copy, imitate or use them without our (or the applicable affiliate’s or licensor’s) prior written consent.


7.1 Changes to Services – We may, at our sole discretion, from time to time and without prior notice to you, modify, suspend or disable, temporarily or permanently, the Services, in whole or in part, for any reason whatsoever.

7.2 No Liability – We will not be liable for any losses suffered by you resulting from any modification to any Services or from any suspension or termination, for any reason, of your access to all or any portion of the Services.

7.3 Effect of Termination – In the event we terminate your Account or your complete access to the Services, we may delete or suspend your Account and all related information and files in such Account.

You agree to receive all communications, agreements, documents, receipts, notices, and disclosures electronically (collectively, “Communications”) that we provide in connection with these Terms of Use, your Account or any Services. You agree that we may provide our Communications to you by, in our sole discretion, posting them on our web-site or by emailing them to you at the email address linked to your Account.

You will defend, indemnify, and hold harmless us, our Affiliates and our Affiliates’ respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers and contractors (collectively, “Indemnified Parties”) from any claim, demand, lawsuit, action, proceeding, investigation, liability, damage, loss, cost or expense, including, without limitation, reasonable attorneys’ fees, arising out of or relating to (a) your use of, or conduct in connection with, the Services; (b) the transfer of your tokens to third parties; (c) any Ethereum Blockchain assets associated with your Ethereum Address; (d) any feedback or user content you provide when accessing the Services, if any; (e) your violation of these Terms; or (f) your infringement or misappropriation of the rights of any other person or entity. If you are obligated to indemnify any Indemnified Party, Digital Block Real Estate Developments (or, at its discretion, the applicable Indemnified Party) will have the right, in its sole discretion, to control any action or proceeding and to determine whether Digital Block Real Estate Developments wishes to settle, and if so, on what terms.


10.1 To the maximum extent permitted under Applicable Law, the Services (and any of their content or functionality) provided by or on behalf of us are provided on an “AS IS” and “AS AVAILABLE” basis, and we expressly disclaim, and you waive, any representations, conditions or warranties of any kind, whether express or implied, legal, statutory or otherwise, or arising from statute, otherwise in law, course of dealing, or usage of trade, including, without limitation, the implied or legal warranties and conditions of merchantability, merchantable quality, quality or fitness for a particular purpose, title, security, availability, reliability, accuracy, quiet enjoyment and non-infringement of third party rights. Without limiting the foregoing, we do not represent or warrant that the Services (including any data relating thereto) will be uninterrupted, available at any particular time or error-free. Further, we do not warrant that errors in the Services are correctable or will be correctable.

10.2 You acknowledge that your data may become irretrievably lost or corrupted or temporarily unavailable due to a variety of causes, and agree that, to the maximum extent permitted under Applicable Law, we will not be liable for any loss or damage caused by denial-of-service attacks, software failures, viruses or other technologically harmful materials (including those which may infect your computer equipment), protocol changes by third party providers, Internet outages, force majeure events or other disasters, scheduled or unscheduled maintenance, or other causes either within or outside our control.

10.3 The disclaimer of implied warranties contained herein may not apply if and to the extent, such warranties cannot be excluded or limited under the Applicable Law of the jurisdiction in which we reside.


In no event shall we (together with our Affiliates, including our and our Affiliates’ respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors) be liable for any incidental, indirect, special, punitive, consequential or similar damages or liabilities whatsoever (including, without limitation, damages for loss of data, information, revenue, goodwill, profits or other business or financial benefit) arising out of or in connection with the Services (and any of their content and functionality), any performance or non-performance of the Services, your Ether, DBRE, Dashboard or any other product, service or other item provided by or on behalf of us, whether under contract, tort (including negligence), civil liability, statute, strict liability or under any other theory of liability, and whether or not we have been advised of, knew of or should have known of the possibility of such damages and notwithstanding any failure of the essential purpose of these Terms of Use or any limited remedy hereunder.


The interpretation and enforcement of these Terms of Use, and any dispute related to these Terms of Use or the Services, will be governed by and construed and enforced in accordance with the laws of the British Virgin Islands, as applicable, without regard to conflict of law rules or principles that would cause the application of the laws of any other jurisdiction. You agree that we may initiate a proceeding related to the enforcement or validity of our intellectual property rights in any court having jurisdiction and you waive any objection to venue in any such court.


13.1 Remedies – Any right or remedy of Digital Block Real Estate Developments set forth in these Terms of Use is in addition to, and not in lieu of, any other right or remedy whether described in these Terms of Use, and terms incorporated by reference herein, under Applicable Law, at law or in equity.

13.2 Affiliates and Contractors – The Services may be operated or provided by us, our Affiliates, or our or our Affiliates’ respective subcontractors. To the extent that one of our Affiliates or subcontractors, is operating or providing any Services, the Affiliate or subcontractor’s provision of such Services will be under terms identical to these Terms, substituting the Affiliate or subcontractor’s name wherever we are referenced in these Terms of Use.

13.3 Non-waiver – Our failure or delay in exercising any right, power, or privilege shall not operate as a waiver thereof.

13.4 Severability – The invalidity or unenforceability of any of these Terms of Use shall not affect the validity or enforceability of any other of these Terms of Use, all of which shall remain in full force and effect.

13.5 Force Majeure – We will have no responsibility or liability for any failure or delay in performance of the Services, or any loss or damage that you may incur, due to any circumstance or event beyond our control, including without limitation any flood, extraordinary weather conditions, earthquake, or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications, power failure, or equipment or software malfunction.

13.6 Assignment – You may not assign or transfer any right to use your Account or the Services, or any of your rights or obligations under these Terms of Use, without our prior written consent, including by operation of law or in connection with any change of control. We may assign or transfer any or all of our rights or obligations under these Terms of Use, in whole or in part, without notice or obtaining your consent or approval.

13.7 Restrictions – We may, at any time and in our sole discretion, restrict your access to, or otherwise impose conditions or restrictions upon your use of the Services without prior notice. For example, we may restrict access to or certain transaction requests from certain locations if we have a reasonable suspicion of fraud, diminished capacity, inappropriate activity or a dispute in connection with your Account.

13.8 No Broker, Legal or Fiduciary Relationships – Digital Block Real Estate Developments is not a provider of a broker, legal, intermediary, agent, or advisory services and has no fiduciary relationship or obligation to you regarding any of  your decisions or activities that you affect when using the Services. Neither our communications nor any information that we provide to you is intended as, or shall be considered or construed as an advice.

13.9 Headings – Headings of sections are for convenience only and shall not be used to limit or construe such sections.

13.10 Entire Agreement – These Terms contain the entire agreement, and supersede all prior and contemporaneous understandings between the parties regarding the Services.

AML and KYC Policy

Digital Block Real Estate Developments Limited
Anti-Money Laundering (AML) and Know Your Client (KYC) Policy:

Last revised: 30.11.21

1. Firm Policy
It is the policy of the Digital Block Real Estate Developments Limited, consisting of several legal entities within several jurisdictions (hereinafter collectively referred to as “the firm” or “the company”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the law and implementing regulations within the company’s existing projects.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveller’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, Ponzi schemes, cybercrime and other investment-related fraudulent activity.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable regulations and authorised body rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

2. AML Compliance Person Designation and Duties
The firm has designated a compliance officer as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. A compliance officer shall be appointed by company’s director or board of directors. The compliance officer has a working knowledge of the implementing regulations and is qualified by experience, knowledge and training. The duties of the AML Compliance Person will include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees, and any other duties decided by the director. The AML Compliance Person will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious Activity Reports (SARs) are filed with the authorized body when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program.

The firm will provide the authorized body with contact information for the AML Compliance Person, including: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile (if any). The firm will promptly notify the authorized body of any change in this information and will review, and if necessary update, this information within 17 business days after the end of each calendar year. The annual review of authorized body information will be conducted by the compliance officer and will be completed with all necessary updates being provided no later than 17 business days following the end of each calendar year. In addition, if there is any change to the information, the compliance officer will update the information promptly, but in any event not later than 30 days following the change.

3. Giving AML Information to the authorized body and Financial Institutions
Authorized body Requests

We will respond to an authorized body request concerning accounts and transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity or organization named in the Request. We understand that we have 14 days (unless otherwise specified by the respective authorized body) from the transmission date of the request to respond to a Request.

If the compliance officer searches our records and does not find a matching account or transaction, then the compliance officer might not reply to the Request. We will maintain documentation that we have performed the required search by printing a search self-verification document confirming that your firm has searched the subject information against your records OR maintaining a log showing the date of the request, the number of accounts searched, the name of the individual conducting the search and a notation of whether or not a match was found.

We will not disclose the fact that the authorized body has requested or obtained information from us, except to the extent necessary to comply with the information request. The compliance officer will review, maintain and implement procedures to protect the security and confidentiality of requests from the authorized body similar to those procedures established to satisfy the requirements of the law with regard to the protection of customers’ nonpublic information.
We will direct any questions we have about the Request to the requesting law enforcement agency as designated in the request.
Unless otherwise stated in the Request, we will not be required to treat the information request as continuing in nature, and we will not be required to treat the periodic Requests as a government provided a list of suspected terrorists for purposes of the customer identification and verification requirements.
We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, for the authorized body, by segregating it from the firm’s other books and records.
We also will employ procedures to ensure that any information received from another financial institution shall not be used for any purpose other than:

  • identifying and, where appropriate, reporting on money laundering or terrorist activities;
  • determining whether to establish or maintain an account or to engage in a transaction; or
  • assisting the financial institution in complying with performing such activities.
  • Checking the Office of Foreign Assets Control Listings
    Before opening an account, and on an ongoing basis, the compliance officer will check to ensure that a customer does not appear on the SDN list or is not engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by the authorized body. Because the list and listings of economic sanctions and embargoes are updated frequently, we will consult them on a regular basis and subscribe to receive any available updates when they occur. With respect to the SDN list, we may also access that list through various software programs to ensure speed and accuracy. The compliance officer will also review existing accounts against the SDN list and listings of current sanctions and embargoes when they are updated and the compliance officer will document the review.
    If we determine that a customer is on the SDN list or is engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by authorized body, we will reject the transaction and/or block the customer’s assets and file a blocked assets and/or rejected transaction form with authorized body within 10 days.

5. Know Your Customer
In addition to the information we must collect under the laws of the jurisdictions where the company operates its projects, we have established a KYC Program. We will collect certain minimum customer identification information from each customer who opens an account for any of our projects; utilize risk-based measures to verify the identity of each customer who opens an account; record customer identification information and the verification methods and results; provide the required adequate KYC notice to customers that we will seek identification information to verify their identities; and compare customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government or respective international authority.

  • Required Customer Information

Prior to opening an account for any of its projects, Digital Block Real Estate Developments Limited will collect the following information for such accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account:
(1) the full name;
(2) date of birth (for an individual);
(3) an address, which will be a residential or business street address (for an individual), or residential or business street address of next of kin or another contact individual (for an individual who does not have a residential or business street address), or a principal place of business, local office, or other physical location (for entities); and
(4) an identification number, which may be:
a) national or international ID (which must not expire within the next 3 months of the submission date);
b) a taxpayer identification number,
c) driver’s license (national or international);
d) any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard.
(5) customer’s contact telephone number and e-mail address;
(6) cutomer’s Ethereum wallet address under which, in combination with the information collected above, we will be able to identify any of our customers and transactions they make within our projects.
(7) OPTIONALLY, for some of our projects, we will collect from our USA-based customers an information to prove their status of accredited investors via filling of our Accredited Investor Questionnaire.
In regards to the customers who are the legal entities, in addition to point (3) above, we will collect the following information/documents:
(8) statutory documents;
(9) description of their corporate structure;
(10) information on theirs beneficial owners and core management (directors or members of the board of directors);
(11) documents from their local financial institutions (e.g. banks) to prove their financial credibility and good reputation.
When opening an account for a foreign business or enterprise that does not have an identification number, we will request alternative government-issued documentation certifying the existence of the business or enterprise.

  • Customers Who Refuse to Provide Information

If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our firm will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML Compliance Person will be notified so that we can determine whether we should report the situation to the authorized body.

  • Verifying Information

Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers. The compliance officer or the engaged third-party AML/KYC compliance services providers will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).

We will verify customer identity through documentary means and, non-documentary means. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means in circumstances where we consider the level of risk is high or if we are still uncertain about whether we know the true identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the customer’s name, street address, zip code, telephone number (if provided), date of birth and Social Security number, allow us to determine that we have a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies). Appropriate documents for verifying the identity of customers include the following:

(a) For an individual: (i) an unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport and (ii) a document verifying current residential address which is not more than 3 months old (i.e. original utility bill, copy of bank or credit card statements etc.); and

(b) For a person other than an individual: (i) documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement or a trust instrument; (ii) a copy of the register of directors, partner list or names of current trustees or equivalent; and in respect of each director, partner, trustee and each beneficial owner of the person holding or being entitled to 10% or more of the ownership interests of that person, the individual evidence of identity documents set out at (a) above in respect of individuals;

Copies of documents provided should be certified by an appropriate professional or notarized as true copies.

We understand that we are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on a government-issued identification as verification of a customer’s identity. If, however, we note that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity.
We will use the following non-documentary methods of verifying identity:

  • Independently verifying the customer’s identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database or another source;
  • Checking references with other professional persons and/or financial institutions; or
  • Obtaining a financial statement.
  • and other non-documentary methods, if applicable.

We will use non-documentary methods of verification when:
(1) we consider the level of risk in respect of the circumstances of a particular customer are high (e.g. where the customer is a politically exposed person (“PEP”) or commercially exposed person (“CEP”) or has some connection with a sanctioned country – see further below);
(2) the customer is unable to present an unexpired government-issued identification document with a photograph or other similar safeguard;
(3) the firm is unfamiliar with the documents the customer presents for identification verification;
(4) the customer and firm do not have face-to-face contact; and
(5) there are other circumstances that increase the risk that the firm will be unable to verify the true identity of the customer through documentary means.

We will verify the information within a reasonable time before or after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we may, pending verification, restrict the types of transactions or money amount of transactions. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we will, after internal consultation with the firm’s AML Compliance Person, file a SAR in accordance with applicable laws and regulations (which in the case of the British Virgin Islands (“BVI”) would mean filing an External SAR in the approved form with the BVI Financial Investigation Agency (“FIA”) – such approved form may be found on the website of the FIA).

We recognize that the risk that we may not know the customer’s true identity may be heightened for certain types of accounts, such as an account opened in the name of a corporation, partnership or trust that is created or conducts substantial business in a jurisdiction that has been designated by the authorities as a primary money laundering jurisdiction, a terrorist concern, or has been designated as a non-cooperative country or territory. We will identify customers that pose a heightened risk of not being properly identified. We will also take the following additional measures that may be used to obtain information about the identity of the individuals associated with the customer when standard documentary methods prove to be insufficient.

  • Lack of Verification

When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) not open an account; (2) impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity; (3) close an account after attempts to verify a customer’s identity fail; and (4) determine whether it is necessary to file a SAR in accordance with applicable laws and regulations.

  • Recordkeeping

We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain documents that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer’s identity for five years after the record is made.

  • Comparison with Government-Provided Lists of Terrorists

At such time as we receive notice that a respective government or international agency has issued a list of known or suspected terrorists and identified the list as a list for KYC purposes, we will, within a reasonable period of time after an account is opened (or earlier, if required by another law or regulation or directive issued in connection with an applicable list), determine whether a customer appears on any such list of known or suspected terrorists or terrorist organizations issued by any government agency and designated as such by functional regulators. We will follow all directives issued in connection with such lists.
We will continue to comply separately with rules prohibiting transactions with certain foreign countries or their nationals.

  • Notice to Customers

We will provide notice to customers that the firm is requesting information from them to verify their identities, as required by law. We will use the following method to provide notice to customers: online.

  • Reliance on Another Financial Institution for Identity Verification.

We may, under the following circumstances, rely on the performance by another financial institution (including an affiliate) of some or all of the elements of our KYC with respect to any customer that is opening an account or has established an account or similar business relationship with the other financial institution to provide or engage in services, dealings or other financial transactions:

  • when such reliance is reasonable under the circumstances;
  • when the other financial institution is subject to a rule implementing the anti-money laundering compliance program requirements and is regulated by a functional regulator in jurisdiction recognized as compliant internationally (including by the FIA ); and
  • when the other financial institution has entered into a contract with our firm requiring it to certify annually to us that it has implemented its anti-money laundering program and that it will perform (or its agent will perform) specified requirements of the customer identification program.

6. Customer Due Diligence Rule
In addition to the information collected under the law, we have established, documented and maintained written policies and procedures reasonably designed to identify and verify beneficial owners of legal entity customers and comply with other aspects of the Customer Due Diligence (CDD) Rule. We will collect certain minimum CDD information from beneficial owners of legal entity customers as described above. We will understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile. We will conduct ongoing monitoring to identify and report suspicious transactions, and, on a risk basis, maintain and update customer information.

  • Identification and Verification of Beneficial Owners

At the time of opening an account for a legal entity customer, the compliance officer will identify any individual that is a beneficial owner of the legal entity customer by identifying any individuals who directly or indirectly own 10% or more of the equity interests of the legal entity customer, and any individual with significant responsibility to control, manage, or direct a legal entity customer. The following information will be collected for each beneficial owner:
(1) the name;
(2) date of birth (for an individual);
(3) an address, which will be a residential or business street address (for an individual), or residential or business street address of next of kin or another contact individual (for an individual who does not have a residential or business street address), or a principal place of business, local office, or other physical location (for a person other than an individual); and
(4) an identification number, which will be a taxpayer identification number, or one or more of the following: a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard.
For verification, we will describe any document relied on (noting the type, any identification number, place of issuance and, if any, date of issuance and expiration). We will also describe any non-documentary methods and the results of any measures undertaken.

  • Identification and verification of the politically exposed persons (PEPs) or commercially exposed persons (CEPs)

At the time of opening an account for an individual or legal entity customer, the compliance officer will identify any individual that is a politically exposed or commercially exposed person or have relation to a politically or commercially exposed person.
In such a case the compliance officer will communicated a customer who have identified him as PEP or CEP or have a relation to PEP or CEP for clarification of his/her purpose of utilization of the company’s project(-s) and request additional documents and information from respective financial institutions where such PEP or CEP or a person related to PEP or CEP is a client.

As regards to the legal entities, our compliance officer or a third party KYC/AML compliance services provider will identify PEPs or CEPs in management or beneficiaries of such legal entities during the KYC verification procedure. In such a case our compliance officer will contact the legal entity to retain additional information on respective PEPs or CEPs.

  • Understanding the Nature and Purpose of Customer Relationships

We will understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile through legal methods.

  • Conducting Ongoing Monitoring to Identify and Report Suspicious Transactions

We will conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update customer information, including information regarding the beneficial ownership of legal entity customers, using the customer risk profile as a baseline against which customer activity is assessed for suspicious transaction reporting.

7. Monitoring Accounts for Suspicious Activity
We will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. The customer risk profile will serve as a baseline for assessing potentially suspicious activity. The AML Compliance Person or his or her designee will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out and will report suspicious activities to the appropriate authorities.
The AML Compliance Person or his or her designee will conduct an appropriate investigation and review relevant information from internal or third-party sources before a SAR is filed.

  • Emergency Notification to Law Enforcement by Telephone

In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately call an appropriate law enforcement authority. If we notify the appropriate law enforcement authority of any such activity, we must still file a timely SAR.

  • Red Flags

Red flags that signal possible money laundering or terrorist financing include, but are not limited to:

Customers – Insufficient or Suspicious Information

  • Provides unusual or suspicious identification documents that cannot be readily verified.
  • Reluctant to provide complete information about nature and purpose of business, prior banking relationships, anticipated account activity, officers and directors or business location.
  • Refuses to identify a legitimate source for funds or information is false, misleading or substantially incorrect.
  • The background is questionable or differs from expectations based on business activities.
  • Customer with no discernible reason for using the firm’s service.

Efforts to Avoid Reporting and Recordkeeping

  • Reluctant to provide the information needed to file reports or fails to proceed with the transaction.
  • Tries to persuade an employee not to file required reports or not to maintain required records.
  • Unusual concern with the firm’s compliance with government reporting requirements and the firm’s AML policies.

Certain Funds Transfer Activities

  • Crypto/wire transfers to/from the customer’s account in unusually large amounts or without an apparent reason.
  • Crypto/wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose.
  • Certain Securities Transactions
  • Customer engages in prearranged or other non-competitive trading, including wash or cross trades of illiquid securities.
  • Two or more accounts trade an illiquid stock suddenly and simultaneously.
  • Customer journals securities between unrelated accounts for no apparent business reason.
  • A customer has opened multiple accounts with the same beneficial owners or controlling parties for no apparent business reason.
  • Customer’s trading patterns suggest that he or she may have inside information.

Other Suspicious Customer Activity

  • Unexplained high level of account activity with very low levels of securities transactions.
  • Law enforcement subpoenas.
  • Large numbers of crypto/securities transactions across a number of jurisdictions.
  • Buying and selling crypto/securities with no purpose or in unusual circumstances (e.g., churning at customer’s request).
  • No concern regarding the cost of transactions or fees (i.e., surrender fees, higher than necessary commissions, etc.).

Responding to Red Flags and Suspicious Activity
When an authorized employee of the firm detects any red flag or other activity that may be suspicious, he or she will notify the compliance officer. Under the direction of the AML Compliance Person, the firm will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or filing a SAR.

IT IS VERY IMPORTANT TO NOTE that where we suspect a person to be engaged in suspicious activity we must not disclose or communicate to that person our suspicion, because that act of disclosure or communication may itself be a criminal offence under certain applicable legislation, the offence of tipping off.

8. Suspicious Transactions and Reporting
Filing a SAR
We will file SARs with the authorized body for any transactions (including and transfers) conducted or attempted by, at or through our firm (either individually or in the aggregate) where we know, suspect or have reason to suspect:
(1) the transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade law or regulation or to avoid any transaction reporting requirement under law or regulation;
(2) the transaction is designed, whether through structuring or otherwise, to evade any requirements of the authorized body regulations;
(3) the transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, the possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or
(4) the transaction involves the use of the firm to facilitate criminal activity.
We will also file a SAR and notify the appropriate law enforcement authority in situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes.

We may file a voluntary SAR for any suspicious transaction that we believe is relevant to the possible violation of any law or regulation but that is not required to be reported by us under the SAR rule. It is our policy that all SARs will be reported regularly to the Board of Directors and appropriate senior management, with a clear reminder of the need to maintain the confidentiality of the SAR.

We will report suspicious transactions by completing a SAR, and we will collect and maintain supporting documentation as required by the authorized body regulations. We will file a SAR-SF no later than 30 calendar days after the date of the initial detection of the facts that constitute a basis for filing a SAR. If no suspect is identified on the date of initial detection, we may delay filing the SAR for an additional 30 calendar days pending identification of a suspect, but in no case will the reporting be delayed more than 60 calendar days after the date of initial detection. The phrase “initial detection” does not mean the moment a transaction is highlighted for review. The 30-day (or 60-day) period begins when an appropriate review is conducted and a determination is made that the transaction under review is “suspicious” within the meaning of the SAR requirements. A review must be initiated promptly upon identification of unusual activity that warrants investigation.

We will retain copies of any SAR filed and the original or business record equivalent of any supporting documentation for five years from the date of filing the SAR. We will identify and maintain supporting documentation and make such information available to the authorized body, any other appropriate law enforcement agencies, state securities regulators or upon request.

As mentioned above, we will not notify any person involved in the transaction that the transaction has been reported, except as permitted by the authorized body regulations. We understand that anyone who is subpoenaed or required to disclose a SAR or the information contained in the SAR will, except where disclosure is requested by appropriate law enforcement or regulatory agency, decline to produce the SAR or to provide any information that would disclose that a SAR was prepared or filed. We will notify the authorized body of any such request and our response.

We will maintain records of the following information:
(a) (A) the name of the purchaser;
(B) the date of purchase;
(C) the type(s) of instrument(s) purchased;
(D) the hash number(s) of each of the instrument(s) purchased; and
(E) the amount of money of each of the instrument(s) purchased.
(H) We may ask about additional documents.
(b) We shall keep records required to be kept for a period of five years, and such records shall be made available to the state authorities upon request at any time.

9. AML Recordkeeping
a. Responsibility for Required AML Records and SAR Filing
Our AML Compliance Person and his or her designee will be responsible for ensuring that AML records (including registers of customers who are PEPs and CEPs and a record of all filed SARs) are maintained properly and that SARs are filed as required.

In addition, as part of our AML program, our firm will create and maintain SARs and relevant documentation on customer identity and verification and funds transmittals. We will maintain SARs and their accompanying documentation for at least five years. We will keep other documents according to existing regulations and other recordkeeping requirements, including certain rules that require retention periods.
b. SAR Maintenance and Confidentiality

We will hold SARs and any supporting documentation confidential. We will not inform anyone outside of appropriate law enforcement or regulatory agency about a SAR. We will refuse any subpoena requests for SARs or for information that would disclose that a SAR has been prepared or filed and immediately notify the authorized body of any such subpoena requests that we receive. We will segregate SAR filings and copies of supporting documentation from other firm books and records to avoid disclosing SAR filings. Our AML Compliance Person will handle all subpoenas or other requests for SARs. We may share information with another financial institution about suspicious transactions in order to determine whether we will jointly file a SAR. In cases in which we file a joint SAR for a transaction that has been handled both by us and another financial institution, both financial institutions will maintain a copy of the filed SAR.

10. Applicable laws
In order to be compliant with the AML/KYC regulations for every of the existing Digital Block Real Estate Developments Limited projects, we apply both national (of places where our certain companies are registered or operate, depending on the project) and international regulations.
We monitor the changes of the applicable laws on the annual basis and, if necessary, amend our policies and procedures accordingly.

11. Firm Relationships
We will work closely with the authorized body to detect money laundering. We will exchange information, records, data and exception reports as necessary to comply with AML laws. Our firm will have filed (and kept updated) the necessary annual certifications for such information. As a general matter, we will obtain and use the following exception reports offered by our authorized body in order to monitor customer activity and we will provide the authorized body with proper customer identification and due diligence information as required to successfully monitor customer transactions. We have discussed how each firm will apportion customer and transaction functions and how we will share information and set forth our understanding in a written document. We understand that the apportionment of functions will not relieve either of us from our independent obligation to comply with AML laws, except as specifically allowed under the authorized body and its implementing regulations.

As noted above, in the BVI the authorized body charged with overseeing the investigation of money laundering, and the body with which SARs are to be filed with in is the BVI is the BVI Financial Investigation Agency. SARs to be filed with the BVI FIA are to be in the approved form for an External SAR found on the website of the FIA.

12. Training Programs
We will develop ongoing employee training under the leadership of the AML Compliance Person and senior management. Our training will occur on at least an annual basis. It will be based on our firm’s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.

Our training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags for analysis and, where appropriate, the filing of SARs); (3) what employees’ roles are in the firm’s compliance efforts and how to perform them; (4) the firm’s record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance with the regulations.

We will develop training in our firm, or contract for it. Delivery of the training may include educational pamphlets, videos, intranet systems, in-person lectures and explanatory memos. We will maintain records to show the persons trained, the dates of training and the subject matter of their training.
We will review our operations to see if certain employees, such as those in compliance, margin and corporate security, require specialized additional training. Our written procedures will be updated to reflect any such changes.

13. Monitoring Employee Conduct and Accounts
We will subject employee accounts to the same AML procedures as customer accounts, under the supervision of the AML Compliance Person. We will also review the AML performance of supervisors, as part of their annual performance review. The AML Compliance Person’s accounts will be reviewed by the director.

14. Confidential Reporting of AML Non-Compliance
Employees will promptly report any potential violations of the firm’s AML compliance program to the AML Compliance Person unless the violations implicate the AML Compliance Person, in which case the employee shall report to the director. Such reports will be confidential, and the employee will suffer no retaliation for making them.

15. Additional Risk Areas
The firm has reviewed all areas of its business to identify potential money laundering risks that may not be covered in the procedures described above.