The screening behind a clean file.
A $1,000,000 applicant is screened before a single sat moves: identity, integrity, source of funds, on-chain provenance, sanctions, and eligibility. The contribution does not buy a way around due diligence; it sits on the far side of it. This page walks the screening in order, names what disqualifies, and explains why clean provenance, documented up front, is the protection. This is not legal advice.
A program that screens is a program worth joining.
Due diligence is not a hurdle the Freedom Passport puts in front of you; it is the reason a lawful citizenship is worth holding. A program that takes anyone's money is a program whose passport is worth nothing.
The Freedom Passport is established under Legislative Decrees No. 918 and No. 286, administered by The Bitcoin Office in coordination with the Dirección General de Migración y Extranjería (DGME). The digital-asset side, how a Bitcoin or USDT contribution is received and cleared, sits inside the LEAD framework, in force since 2023, supervised by CNAD, the national digital-assets commission. Every file runs through anti-money-laundering and counter-terrorist-financing (AML/CTF) due diligence before the state grants citizenship. The grant comes after the screen, never before it.
For a Bitcoiner this is good news, not a burden. The same scrutiny that keeps illicit money out is what makes the passport defensible at a border, durable across an administration, and clean enough to pass to your children. A clean, documented applicant is precisely who the program wants. The work is to arrive that way, and that is the licensed agent's job: to compile, document, and file a fully disclosed application that clears on the facts. The source-of-funds detail sits on the source-of-funds page, and the paperwork on the document checklist.
What a $1,000,000 applicant actually goes through.
Screening is not one check; it is five, run in sequence. The early layers are gates: an applicant who fails eligibility or sanctions never reaches the provenance review. The later layers are where a well-prepared file is won or lost on documentation.
Verify who you are
Passport, biometrics, and proof of address are verified against the applicant. Documents are checked for authenticity and consistency. Each family member on the file is verified individually. This is the foundation; everything that follows is tied to a confirmed identity.
Background and character
Criminal-record checks, adverse-media screening, and politically-exposed-person (PEP) status. A PEP designation is not disqualifying on its own; it raises the documentation standard. A serious adverse criminal or integrity finding can end a file.
Where the money came from
The $1,000,000 must be evidenced to a lawful origin: salary, business proceeds, sale of an asset, inheritance, or investment gains, each tied to records. Unexplained wealth does not clear. The provenance is built before the contribution moves, not reconstructed after.
Where the Bitcoin came from
For a Bitcoin contribution, the coins are traced on-chain to a lawful origin and the wallet path is screened against known illicit sources. Coins bought on a KYC exchange, or mined with documented operations, present clean. This layer is unique to a Bitcoin-denominated program.
OFAC and watchlists
The applicant, every family member on the file, and the contributing wallet path are screened against the U.S. Treasury OFAC SDN list and equivalent international sanctions and watchlists. A sanctions hit is disqualifying, full stop.
Restricted nationalities and regions
Run at the very start: nationals of Cuba, North Korea, Iran, and Syria, residents of Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia, and OFAC-sanctioned persons are not eligible. A clean source of funds cannot cure an ineligible status.
The hard lines, stated plainly.
Some restrictions are absolute and screened before anything else. They are not negotiable, and no quality of source-of-funds documentation can move them. Here they are, on the record.
The first three are status restrictions: a nationality, a region of residence, or a sanctions designation. They cannot be cured by documentation and are screened before a file proceeds. The last two are file restrictions: they are about whether the money and the coins can be evidenced, and a well-prepared applicant resolves them before submission. Eligibility is determined by the authorities on the file; this page is informational and not legal advice. The full paperwork sits on the document checklist.
Clean coins tell their own story.
A Bitcoin-denominated program adds a layer no fiat program has: the contribution itself carries a verifiable history. That is an advantage for the honest holder and a wall for everyone else.
On-chain provenance review traces the contributing coins back to a lawful origin and ties that history to off-chain records. The questions are concrete: how were the coins acquired, and does the chain agree with the paperwork. Coins bought on a KYC exchange with account statements, coins mined with documented operations and electricity invoices, coins received as earned income with contracts, or coins from the sale of an asset with a bill of sale: each presents a clean path. The wallet history is then screened against known illicit sources, sanctioned mixers, darknet markets, stolen-funds clusters, ransomware addresses, so that a clean origin is confirmed rather than assumed.
Good provenance is not something you produce under pressure after the contribution. It is something you carry into the room, documented, before a single sat moves.
This is where a Bitcoiner who has held responsibly has a genuine edge. A self-custodied stack acquired on regulated venues, with statements kept and acquisition dated, is the cleanest source of funds a program can ask for, because the ledger is public and the paper trail confirms it. The work is documentation, not obfuscation. Coins run through a sanctioned mixer to hide their path do the opposite of help; they convert a clean holding into a flagged one. The detail on building this file sits on the source-of-funds page, and the mechanics of paying in Bitcoin on the pay-in-Bitcoin page.
The rules behind the digital-asset side.
The screening does not happen in a vacuum. It runs inside a defined legal architecture: the program decrees, the migration authority, and the digital-asset regime that governs how a Bitcoin or USDT contribution is received and cleared.
Decrees No. 918 & No. 286
The Freedom Passport is established under Legislative Decrees No. 918 and No. 286, administered by The Bitcoin Office in coordination with the DGME. The citizenship is granted by the state after due diligence, not sold as a product.
The digital-asset law
The LEAD framework, in force since 2023, governs digital assets in El Salvador: how providers operate, how a Bitcoin or USDT contribution is received, and the AML/CTF standards the contribution must meet on its way in.
The supervising commission
CNAD, the national digital-assets commission, licenses and supervises digital-asset service providers under LEAD. The same regulatory architecture that governs the providers surrounds the Freedom Passport contribution.
The licensed filer
21 CBI, operating as Bitcitizen LLC, is a Licensed Agent authorized by Director Stacy Herbert of The Bitcoin Office, valid 27 February 2026 to 26 February 2027. The agent compiles and files a clean application; the authorities decide it.
The agent compiles the file. The provenance does the defending.
A licensed agent does not approve your application and cannot promise that anyone will; an agent who guarantees approval before screening is one to avoid. What the agent does is build the file that clears on the facts: verify identity, assemble the background and integrity record, document the source of funds, trace and evidence the on-chain provenance, run the sanctions and eligibility screens early, and file a clean, fully disclosed application through an authorized channel. The files challenged anywhere in the world are the ones that went around the law, undisclosed records, unauthorized channels, a source of funds that does not survive scrutiny. The protection is the disclosure. As Adam Juchniewicz, CEO of 21 CBI, puts it: good provenance, documented before the contribution moves, is the single best protection an applicant has, because a clean file has nothing to unravel later. This page is informational, not legal or tax advice.
The screening questions.
What due diligence does an El Salvador Freedom Passport applicant go through?
A $1,000,000 applicant is screened across five layers: identity verification (passport, biometrics, proof of address), background and integrity checks (criminal record, adverse media, politically exposed person status), source-of-funds and on-chain provenance review, sanctions and OFAC screening, and an eligibility check against the restricted nationalities and regions. The digital-asset side is governed by the LEAD framework, supervised by CNAD. The licensed agent compiles the file, documents the provenance, and files a clean, fully disclosed application. Good provenance is the protection.
Who is ineligible for the El Salvador Freedom Passport?
Nationals of Cuba, North Korea, Iran, and Syria are not eligible. Residents of Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia are not eligible. Persons sanctioned by OFAC, or who appear on equivalent designated-person lists, are not eligible. These are hard restrictions screened at the start; a clean source of funds cannot cure an ineligible nationality, region of residence, or sanctions designation. This is not legal advice; eligibility is determined by the authorities on the file.
How is clean Bitcoin provenance assessed for the Freedom Passport?
On-chain provenance review traces the coins back to a lawful origin. The agent documents how the Bitcoin was acquired (exchange purchase, mining, earned income, or sale of an asset), ties on-chain history to off-chain records, and screens the wallet path against known illicit sources such as sanctioned mixers, darknet markets, and stolen-funds clusters. Coins bought on a KYC exchange with statements, or mined with documented operations, present clean. The honest position is that provenance is built before the contribution moves, not reconstructed after.
What is OFAC and sanctions screening in the Freedom Passport process?
Every applicant is screened against the U.S. Treasury OFAC Specially Designated Nationals list and equivalent international sanctions and watchlists. The screen covers the applicant, family members included on the file, and the wallet path of the contributing Bitcoin. A sanctions hit is disqualifying. This protects the program and the applicant: a clean file that clears sanctions screening at the outset is one that does not unravel later. Sanctions determinations rest with the authorities, not the advisor.
What is the LEAD framework and CNAD in the due-diligence process?
LEAD is El Salvador's digital-asset law, in force since 2023, and CNAD is the national digital-assets commission that supervises it. Together they govern the digital-asset side of the Freedom Passport: how a Bitcoin or USDT contribution is received, how providers are licensed, and the AML/CTF standards the contribution must meet. The Freedom Passport itself is established under Legislative Decrees No. 918 and No. 286 and administered by The Bitcoin Office in coordination with the DGME.
Does the licensed agent guarantee approval of my Freedom Passport application?
No. The licensed agent compiles, documents, and files a clean, fully disclosed application; the agent does not approve it. 21 CBI, operating as Bitcitizen LLC, is a Licensed Agent authorized by Director Stacy Herbert of The Bitcoin Office, valid 27 February 2026 to 26 February 2027. The authorization lets the agent submit and process files; the grant of citizenship rests with the authorities after due diligence. An agent who promises approval before screening is one to avoid.
What disqualifies a Freedom Passport application?
An ineligible nationality (Cuba, North Korea, Iran, Syria) or region of residence (Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia) is disqualifying. An OFAC or equivalent sanctions designation is disqualifying. A source of funds that cannot be evidenced, or Bitcoin whose on-chain path leads to sanctioned mixers, darknet markets, or stolen-funds clusters, will not clear. Material non-disclosure, a falsified document, or a serious adverse criminal or integrity finding will end a file. The honest answer is that the program screens to protect itself, and a clean, documented applicant is exactly who it wants.
How long does the Freedom Passport due-diligence process take?
The full Freedom Passport process runs six to eight weeks and is completed remotely; no relocation is required. Due diligence runs through that window, with the heaviest work front-loaded into compiling the identity, background, source-of-funds, and provenance file before submission. A file that arrives clean and fully documented moves; a file with gaps generates follow-up requests that extend the timeline. Citizenship is permanent and hereditary, and one in-country visit is required every five years. See the timeline page for the week-by-week view.
Document first. File clean.
The strongest application is the one that clears on the facts: identity verified, source of funds evidenced, provenance traced, sanctions and eligibility screened early. Before any contribution, book a confidential session with Adam, where the first call goes straight to your file and your provenance, not a sales script.