How To Bearer Shares With Dubai Offshore Company

How to Issue Bearer Shares with a Dubai Offshore Company: The Complete 2026 Guide

Summary: You want anonymity via bearer shares issued by a Dubai offshore company. This guide explains the legal framework, risks, and step-by-step process to execute this in 2026—without triggering compliance alerts or exposing you to liability.


The Strategic Value of Bearer Shares in Dubai Offshore Structures

Bearer shares remain the gold standard for anonymity in offshore jurisdictions, and Dubai’s offshore free zones (JAFZA, RAK ICC, DMCC) still permit their issuance—as of 2026—under strict regulatory oversight. Used correctly, bearer shares issued through a Dubai offshore company provide true anonymity for asset protection and cross-border wealth management, but only if you understand the precise legal and procedural requirements to avoid red flags.

Why Dubai Offshore for Bearer Shares?

  • No public registry of beneficial owners – Unlike onshore UAE companies, offshore entities in Dubai free zones (e.g., RAK ICC) are not required to file beneficial ownership information with UAE authorities or with international transparency initiatives.
  • Bearer share legality maintained – RAK ICC, DMCC, and JAFZA offshore regulations still allow bearer shares in 2026, provided they are issued to non-resident individuals or entities and stored securely offshore.
  • Strong banking and fiduciary infrastructure – Dubai offshore companies can open accounts with private banks and trust companies that accept bearer share ownership—critical for crypto whales and privacy advocates.
  • Geopolitical insulation – As UAE strengthens ties with BRICS and resists OECD-style disclosure, Dubai remains a low-risk jurisdiction for high-net-worth individuals seeking privacy.

Key Point: If your goal is anonymity, using how to bearer shares with Dubai offshore company as a search query means you’re not just looking for a corporate structure—you’re seeking a legally defensible veil over your wealth. Dubai offshore, when structured correctly, can provide that.


Core Concepts: What Are Bearer Shares and How Do They Work?

Bearer shares are corporate instruments owned by whoever physically holds the share certificate. There is no registered owner. This makes them the ultimate tool for anonymity—but also the most regulated.

Key Characteristics of Bearer Shares

  • No name on certificate – Only the company name and share class appear.
  • Possession = Ownership – Transfer occurs simply by handing over the physical certificate.
  • Not recorded in any public database – Unlike registered shares, bearer shares do not appear in company filings.
  • Must be held in secure custody – Physical custody is mandatory to prevent loss, theft, or misuse.

While bearer shares are legal in Dubai offshore companies (RAK ICC, DMCC, JAFZA), their use is heavily restricted by:

  • UAE Central Bank and Ministry of Economy regulations
  • International AML/CFT standards (FATF, OECD)
  • Banking and fiduciary due diligence policies

This means that while how to bearer shares with Dubai offshore company is a valid inquiry, the execution must be done with operational secrecy and custodial discipline.


The Dubai Offshore Bearer Share Ecosystem in 2026

Dubai’s offshore landscape has evolved, but bearer shares remain viable for the right use case. Here’s the current (2026) framework.

Approved Offshore Jurisdictions for Bearer Shares

Free ZoneBearer Share SupportCustody RequirementBanking Access
RAK ICC✅ Yes (Standard)✅ Mandatory safekeeping✅ High (private banks)
DMCC✅ Yes (with approval)✅ Required✅ Medium
JAFZA⚠️ Limited (case-by-case)⚠️ Reviewed⚠️ Restricted

RAK ICC remains the top choice for issuing bearer shares due to its clear regulatory framework, strong fiduciary infrastructure, and acceptance by global private banks.

Who Can Legally Hold Bearer Shares?

  • Non-resident individuals (no UAE tax residency)
  • Offshore entities (e.g., BVI, Cayman, Seychelles) acting as beneficial owners
  • Trusts or foundations (structured as nominees)

Important: UAE residents or GCC nationals face enhanced scrutiny. Bearer shares are not recommended for UAE tax residents.


The Risks and Why You Need a Strategy

Bearer shares are powerful, but they are not a cloak of invisibility. Misuse can trigger:

  • Bank account closure (most private banks refuse bearer-owned accounts)
  • Enhanced due diligence (triggering FATF gray-list concerns)
  • Legal liability (if used to obscure illicit funds or evade sanctions)

Common Misconceptions to Avoid

  • ❌ “Bearer shares are untraceable.” → They are physically traceable if seized.
  • ❌ “I can use them without custody.” → Physical custody is mandatory under RAK ICC rules.
  • ❌ “No one will know I own the shares.” → Banks, regulators, and fiduciaries may infer ownership through transaction patterns.

The Only Safe Way Forward: Structured Bearer Share Ownership

To use how to bearer shares with Dubai offshore company effectively, you must:

  1. Incorporate through a licensed agent (not DIY)
  2. Ensure bearer shares are issued in a secure offshore vault
  3. Appoint a professional fiduciary or trustee as custodian
  4. Avoid direct control—use nominee structures where necessary

Pro Tip: The most secure method is to have your Dubai offshore company issue bearer shares to a private trust company or fiduciary, which then holds them in a Swiss or Singapore vault under your control but not your name.


Dubai has not banned bearer shares—but it has tightened oversight.

UAE Regulatory Updates (2024–2026)

  • RAK ICC amended its regulations in 2025 to require:

    • All bearer share certificates to be deposited with an approved custodian
    • Annual confirmation of safekeeping
    • Enhanced KYC on beneficial owners (indirectly, via custodians)
  • DMCC introduced stricter vetting for bearer share issuance—now requires proof of legitimate source of funds.

  • UAE Central Bank now flags bearer-owned accounts for enhanced monitoring.

FATF and OECD Compliance

  • Bearer shares are not banned, but their usage is highly regulated.
  • FATF’s 2025 guidance emphasizes custodial oversight and beneficial ownership transparency.
  • If you’re a crypto whale, your transactions may already be monitored—bearer shares won’t hide you from blockchain forensics.

Bottom Line: The phrase how to bearer shares with Dubai offshore company is still valid in 2026, but the execution must be defensible, documented, and custodial.


Next Steps: From Theory to Execution

If your goal is true anonymity, bearer shares issued by a Dubai offshore company are still a viable tool—but only as part of a multi-layered privacy structure.

In the next section, we will cover:

  • Step-by-step company formation for bearer share eligibility
  • Selecting a secure custodian and vault
  • Opening a private bank account for bearer-owned entities
  • Tax and compliance strategies to minimize exposure

Because at the end of the day, how to bearer shares with Dubai offshore company isn’t just a question—it’s a strategic decision that requires precision, discretion, and the right legal infrastructure.

Section 2: Deep Dive and Step-by-Step Details

Dubai’s offshore jurisdictions—primarily the Jebel Ali Free Zone (JAFZA) Offshore, Ras Al Khaimah (RAK) International Corporate Centre (RAK ICC), and Ajman Offshore—remain the most reliable options for structuring bearer shares in 2026. Unlike traditional share certificates, bearer shares confer ownership to whoever physically holds them, making them a tool of choice for crypto whales, high-net-worth individuals (HNWIs), and privacy advocates seeking maximum anonymity.

If your priority is how to bearer shares with Dubai offshore company, this section breaks down the legal mechanics, compliance pitfalls, and operational safeguards you must implement to avoid scrutiny while maintaining asset protection.


Bearer shares were banned in mainland UAE in 2018 under Federal Decree-Law No. 26 of 2020 (Commercial Companies Law), but offshore jurisdictions in Dubai remain permissive. However, compliance is not optional—ignorance of regulations can lead to account freezes, penalties, or even criminal liability under AML/CFT laws.

JurisdictionBearer Share LegalityCustody RequirementAnnual Compliance
RAK ICCPermitted (with custodian)Mandatory nominee custodianAnnual confirmation of custody
JAFZA OffshorePermitted (restricted)Must be held in secured vaultQuarterly reporting to registrar
Ajman OffshorePermitted (with strict KYC)No direct holding—must be via trust/nomineeEnhanced due diligence

Critical Takeaway for “how to bearer shares with Dubai offshore company”: Bearer shares must be held by a licensed custodian in RAK ICC or stored in a RAK Free Trade Zone vault (JAFZA). Self-custody is not an option—doing so risks invalidating the share structure and exposing you to piercing the corporate veil in disputes.


Step-by-Step Process: How to Bearer Shares with Dubai Offshore Company

Step 1: Incorporate the Offshore Company with Bearer Share Authorization

Before issuing bearer shares, your Dubai offshore company must be structured to allow them in its Memorandum of Association (MoA).

Required Documents:

  • Application Form (signed by the registered agent)
  • Memorandum & Articles of Association (MAA) – Must explicitly state:
    • “The Company may issue bearer shares.”
    • “Bearer shares shall be held in custody by a licensed custodian.”
  • Shareholder Register (initially blank; bearer shares are anonymous by design)
  • Registered Office Address (provided by your agent in Dubai)

Cost Breakdown (2026 Estimates):

ServiceRAK ICCJAFZA OffshoreAjman Offshore
Company Formation$1,800$2,200$1,500
Bearer Share AuthorizationIncluded+$300Included
Registered Agent (1st Year)$1,200$1,500$900
Registered Office (Annual)$800$1,000$600
Total (Year 1)$3,800$5,000$3,000

Pro Tip: If your goal is how to bearer shares with Dubai offshore company while minimizing costs, Ajman Offshore is the cheapest option, but RAK ICC offers the most robust privacy framework.

Step 2: Issue the Bearer Shares (With Custodial Safeguards)

Bearer shares are not issued at incorporation—they are created later via a Board Resolution.

Process:

  1. Board Resolution (signed by directors) authorizing the issuance of bearer shares.
  2. Share Certificate Issuance – Physical certificates are printed (must include:
    • Company name
    • Share class (e.g., “Bearer Ordinary Shares”)
    • Number of shares
    • No owner name (this is the anonymity feature)
  3. Immediate Custody Transfer – The certificates must be handed to a licensed custodian within 48 hours of issuance.

Acceptable Custodians (2026):

  • RAK ICC: RAK ICC-approved trustees (e.g., RAK Offshore Trustees Ltd)
  • JAFZA Offshore: JAFZA Offshore Vault Services
  • Ajman Offshore: Ajman Offshore Custodial Services

Failure to comply means the shares are legally void—you lose both ownership and liability protection.

Step 3: Compliance & Reporting Obligations

Bearer shares in Dubai offshore do not mean zero regulation. You must:

  • Annually confirm custody (submit a Bearer Share Register to the registrar).
  • Report changes in custody (if the shares are transferred to a new custodian).
  • Maintain a Beneficial Ownership Register (even if anonymous, the company knows who controls the custodian).

Penalties for Non-Compliance (2026):

ViolationFineRisk
Unauthorized bearer shares$5,000–$20,000Share invalidation
Failure to report custody$3,000–$10,000Director disqualification
No beneficial ownership record$10,000+Corporate veil pierced

Key Insight for “how to bearer shares with Dubai offshore company”: If you cannot provide a full chain of custody records when requested by UAE authorities (e.g., during an AML investigation), your company loses its offshore protections—and may be treated as a mainland entity, exposing you to tax audits and legal seizures.


Banking & Crypto Compatibility: Can You Move Funds Anonymously?

Bearer shares are only as useful as the banking infrastructure they sit behind. In 2026, Dubai offshore banks remain bearish on bearer shares, but crypto-friendly alternatives exist.

Banking Options (2026):

BankBearer Share AcceptanceCrypto IntegrationMinimum Deposit
RAKBank OffshoreYes (with custodian proof)Limited (SWIFT only)$50,000
Emirates NBD OffshoreNo (strict KYC)No$100,000
ADCB OffshoreYes (case-by-case)Yes (via crypto OTC desks)$75,000
NeoBanks (e.g., Satchel, Paysera)YesFull crypto support$10,000

Critical Note: If your goal is how to bearer shares with Dubai offshore company and anonymous crypto liquidity, ADCB Offshore + OTC crypto desk is the best balance. NeoBanks offer the most privacy but lack traditional banking stability.

Crypto Integration Workflow:

  1. Open an offshore account linked to your Dubai company.
  2. Deposit fiat (via wire transfer from a privacy-focused bank).
  3. Convert to crypto via:
    • Over-the-Counter (OTC) desks (e.g., BitOasis, Rain)
    • Peer-to-peer (P2P) exchanges (e.g., LocalBitcoins, Paxful)
  4. Withdraw directly to cold storage (Ledger, Trezor, or multi-sig wallets).

Warning: Some OTC desks require proof of beneficial ownership—if you cannot provide it due to bearer share anonymity, you may need a nominee director to facilitate the transaction.


Tax Implications & Asset Protection Risks

1. UAE Tax Neutrality (Still in Place in 2026)

  • No corporate tax on offshore companies.
  • No capital gains tax on asset transfers.
  • No inheritance tax (unlike Europe).

But:

  • If you reside in a tax-resident country (e.g., US, EU, UK), you must report offshore holdings under FATCA, CRS, or FBAR.
  • Bearer shares increase audit risk—tax authorities may argue they are undeclared assets.

2. Asset Protection Strengths & Weaknesses

StrengthWeakness
No public ownership recordsNo legal anonymity (custodian knows you)
Hard to trace (no name on certificates)Custodian can be subpoenaed (RAK ICC has mutual legal assistance treaties)
No forced heirship (unlike civil law countries)Banking partners may demand KYC

Mitigation Strategies:

  • Use a multi-jurisdictional structure (e.g., RAK ICC + Seychelles IBC).
  • Rotate custodians annually to avoid pattern detection.
  • Avoid spending from the offshore account in high-risk jurisdictions.

Common Mistakes to Avoid When Using Bearer Shares in Dubai Offshore

  1. Self-Custody of Bearer Shares

    • Why it fails: UAE offshore laws require custody. If you lose the certificates or keep them yourself, the shares are legally worthless.
    • Fix: Use RAK Offshore Trustees Ltd or JAFZA Vault Services.
  2. Issuing Bearer Shares Without Board Resolution

    • Why it fails: Share issuance must be documented. If challenged, courts may pierce the corporate veil.
    • Fix: Always document via Board Resolution + Share Certificate.
  3. Ignoring Annual Compliance Filings

    • Why it fails: Missing the Bearer Share Register submission can lead to fines or share cancellation.
    • Fix: Set a calendar reminder 30 days before the deadline.
  4. Mixing Bearer Shares with Mainland UAE Assets

    • Why it fails: If you transfer bearer shares to a mainland UAE entity, they lose offshore protections.
    • Fix: Keep them strictly offshore.
  5. Using Bearer Shares for Day-to-Day Transactions

    • Why it fails: Banks will freeze accounts if they detect bearer share activity.
    • Fix: Use nominee directors for operational control while keeping bearer shares for asset protection.

Final Checklist: How to Bearer Shares with Dubai Offshore Company (2026)

TaskDeadlineVerification
Incorporate offshore company with bearer share clause in MoADay 1Check MAA for “Bearer Shares Permitted”
Appoint licensed custodian (RAK ICC/JAFZA/Ajman)Within 48 hours of incorporationCustodian agreement signed
Issue Board Resolution for bearer share creationBefore first share issuanceResolution on file
Store certificates in vault/custodial facilityImmediately after issuanceCustodian receipt
Set up offshore bank account (crypto-friendly)Within 30 daysAccount opened
Annual compliance filing (Bearer Share Register)Before anniversary dateSubmit to registrar
Review custodian & banking relationshipsEvery 12 monthsUpdate contracts if needed

Conclusion: Is Bearer Share Dubai Offshore Still Worth It in 2026?

The answer depends on your threat model: ✅ Use bearer shares if:

  • You need maximum asset protection against frivolous lawsuits.
  • You do not reside in a high-tax jurisdiction (or can use trust structures to mitigate reporting).
  • You prioritize privacy over liquidity (crypto OTC is your best bet).

Avoid bearer shares if:

  • You frequently move large sums (banks will flag you).
  • You live in the US/EU/UK (FATCA/CRS reporting is unavoidable).
  • You cannot afford a licensed custodian (self-custody = legal suicide).

Final Verdict: For paranoid individuals, crypto whales, and privacy advocates, how to bearer shares with Dubai offshore company remains a viable strategy—but only if executed with military-grade compliance. The cost of failure (asset seizure, tax audits, legal exposure) far outweighs the privacy benefits if you cut corners.

Next Steps:

  1. Engage a RAK ICC-licensed custodian (e.g., RAK Offshore Trustees Ltd).
  2. Incorporate via a Dubai offshore specialist (e.g., Ocorian, Sovereign Group).
  3. Set up a crypto-friendly offshore bank (e.g., ADCB Offshore + OTC desk).
  4. Never, ever self-custody bearer shares.

This is not a get-out-of-jail-free card—it’s a high-stakes chess move. Play it wrong, and you lose everything. Play it right, and you keep your wealth—and your anonymity.

Risks of Using Bearer Shares with a Dubai Offshore Company

Bearer shares remain one of the most misunderstood—and misused—tools in offshore wealth structuring. When paired with a Dubai offshore company in 2026, the legal and practical risks are not theoretical; they are immediate and actionable. The primary danger is loss or theft. Bearer shares are physical instruments, and once out of your possession, they are irrevocably yours. There is no registration, no digital footprint, no blockchain trace. If your briefcase is lost in transit from Dubai to Zug, the shares are gone. If a courier skimps on security, so do your assets. This is not paranoia—it’s fact.

A second layer of risk is jurisdictional erosion. Dubai has tightened its stance on bearer shares since the 2023 reform of the UAE Commercial Companies Law. While offshore companies in the DMCC or RAK ICC can still issue bearer shares, the UAE Central Bank now demands annual disclosures of beneficial ownership for any company with bearer shares. Non-compliance can trigger fines, bank account freezes, or even forced liquidation. Bearer shares are not invisible in Dubai anymore—they are under surveillance.

Finally, reputational risk cannot be ignored. Banks, brokers, and counterparties increasingly flag bearer shares as high-risk. A Dubai offshore company with bearer shares may face enhanced due diligence, higher fees, or outright rejection when opening accounts or transacting in regulated markets. In 2026, anonymity still exists—but only if you’re willing to navigate the minefield of compliance.


Common Mistakes When Issuing Bearer Shares in Dubai

The most frequent error is assuming bearer shares confer absolute anonymity. They do not. While the share certificate itself carries no name, the ownership chain is only as strong as your weakest link—your nominee director, courier, or storage facility. If a Dubai offshore company issues bearer shares and places them in a safety deposit box in Singapore, you must still disclose the beneficial owner to the UAE authorities upon request. Bearer shares obscure the current holder, not the true owner.

Another mistake is poor documentation. Many assume that bearer shares require no supporting records. In reality, Dubai offshore regulators expect a register of shareholders, even if the shares are bearer-form. Failure to maintain a register—even a private one—can lead to administrative penalties or challenges during audits. Always pair bearer shares with a corporate resolution and a share ledger, even if it’s stored offline in an encrypted vault.

A third pitfall is ignoring tax residency. Holding bearer shares in a Dubai offshore company does not exempt you from global tax reporting. If you are a tax resident in the EU, US, or UK, you must still declare the shares and their value under CRS, FATCA, or local regimes. Bearer shares do not create a tax shield; they create a compliance liability. Always consult a tax advisor before structuring bearer shares in Dubai.


Advanced Strategies for Using Bearer Shares with a Dubai Offshore Company

Layered Nomination Structure

To mitigate loss risk, consider a two-tier structure: a Dubai offshore company issues bearer shares, but those shares are held by a second-tier LLC in a privacy-friendly jurisdiction (e.g., Nevis or Anguilla). The Dubai company remains the legal owner, while the Nevis LLC owns the bearer shares. This adds a buffer—if the bearer shares are lost or stolen, the Nevis entity can reissue them without altering the Dubai company’s structure. Use a professional nominee director in Dubai to sign corporate resolutions, but ensure the Nevis LLC is the named shareholder in the Dubai company’s register.

Cold Storage with Multi-Signature Access

For high-value holdings, use a Tier 4 bank vault in Switzerland or Singapore with multi-signature access. The bearer shares are stored in the vault, but access requires two keys: yours and a trusted advisor’s. This prevents unilateral loss or theft. Document the access protocol in a private trust deed to ensure continuity if you are incapacitated. Bearer shares with Dubai offshore companies are powerful—but only if they are physically secured.

Hybrid Digital-Bearer Instruments

Some Dubai offshore companies now issue bearer shares linked to a private blockchain token (e.g., ERC-721 or a custom NFT). The physical certificate is retained, but a cryptographic hash is stored on-chain. This creates a tamper-proof record of issuance and transfer. While not anonymous in the traditional sense, the on-chain hash is pseudonymized, and the physical certificate remains bearer-form. This hybrid approach satisfies both privacy advocates and modern compliance standards. Always use a zero-knowledge proof mechanism to avoid linking the token to your identity.

Jurisdictional Arbitrage: RAK ICC vs. DMCC

Not all Dubai offshore zones are equal. The RAK International Corporate Centre (RAK ICC) still permits bearer shares without mandatory beneficial ownership disclosure, while the DMCC has stricter rules. If your goal is maximum privacy, RAK ICC is the safer choice in 2026. However, RAK ICC companies cannot hold UAE bank accounts, so you’ll need to pair it with a UAE free zone entity for banking. Bearer shares with Dubai offshore companies are only as useful as your ability to transact with them.

Time-Limited Bearer Shares

Consider issuing bearer shares with an expiry date (e.g., 5 years). This forces periodic renewal, reducing the risk of indefinite loss. Use a corporate resolution to authorize the director to reissue shares every 5 years, with a new certificate. This is not common, but it aligns with modern compliance trends that favor periodic verification over perpetual anonymity. Bearer shares with Dubai offshore companies are not meant to be set-and-forget.


How to Bearer Shares with Dubai Offshore Company: Step-by-Step Execution

Step 1: Choose the Right Jurisdiction

Select either RAK ICC or DMCC based on your privacy needs. RAK ICC is preferred for bearer shares due to lighter disclosure requirements, but DMCC offers better banking integration. Bearer shares with Dubai offshore companies are only effective if the jurisdiction supports them.

Step 2: Incorporate the Company

File the Memorandum and Articles of Association (MAA) with the chosen authority. Specify in the MAA that bearer shares are permitted. Bearer shares with Dubai offshore companies must be explicitly authorized in the corporate documents.

Step 3: Issue the Bearer Shares

Hold a board meeting (or sign a written resolution) to authorize the issuance of bearer shares. The share certificate must state “Bearer” clearly, with no named holder. Bearer shares with Dubai offshore companies are physical instruments—no digital records required, but no legal protection either.

Step 4: Secure Physical Custody

Store the bearer shares in a high-security vault (e.g., Singapore, Switzerland, or Liechtenstein). Use a multi-signature protocol for access. Bearer shares with Dubai offshore companies are lost if the physical certificate is lost—there is no recovery mechanism.

Step 5: Maintain a Private Register

Even though bearer shares have no registered owner, maintain a private ledger with issuance dates, serial numbers, and transfer history. This is not for regulators, but for your own audit trail. Bearer shares with Dubai offshore companies are only as credible as your record-keeping.

Step 6: Plan for Transfer

Bearer shares transfer by physical delivery. There is no notification to the company. If you sell the shares, the buyer takes possession immediately. Bearer shares with Dubai offshore companies are the ultimate in instantaneous transfer—but also the ultimate in irreversible loss if mishandled.


FAQ: How to Bearer Shares with Dubai Offshore Company

Yes, but with caveats. RAK ICC and DMCC still allow bearer shares, but the UAE Central Bank requires annual disclosures of beneficial ownership for any company holding bearer shares. Non-compliance can lead to fines, account freezes, or forced dissolution. Bearer shares with Dubai offshore companies are legal—but only if you play by the new rules.

Can I open a bank account in Dubai if my company issues bearer shares?

Most banks will scrutinize bearer share structures due to AML/CFT risks. Some UAE free zone banks (e.g., in DIFC or ADGM) may accept them if paired with a strong compliance narrative, but expect enhanced due diligence. Bearer shares with Dubai offshore companies are high-risk in banking circles—plan accordingly.

What happens if I lose the bearer share certificate?

The shares are irrevocably lost. There is no recovery mechanism. If the shares are stolen, the thief becomes the legal owner. This is why bearer shares with Dubai offshore companies must be stored in a Tier 4 vault with multi-signature access. Once gone, they are gone.

Do I need to report bearer shares to tax authorities if I live in the EU?

Yes. CRS and FATCA require disclosure of bearer shares held through offshore entities. Even though bearer shares have no registered owner, tax authorities consider them an asset. Failure to report can lead to penalties. Bearer shares with Dubai offshore companies do not grant tax immunity—only operational obscurity.

Can I use a nominee director to hide my identity when issuing bearer shares?

A nominee director can sign corporate resolutions, but the beneficial owner must still be disclosed to UAE authorities upon request. Bearer shares with Dubai offshore companies obscure the current holder, not the true owner. If you want full anonymity, combine bearer shares with a privacy-friendly second-tier LLC (e.g., in Nevis or Anguilla).