Anti-Money Laundering Policy

This Anti-Money Laundering Policy explains Pementek's approach to preventing money laundering, terrorist financing, sanctions evasion, fraud and other prohibited financial activity across its payment and payout infrastructure.

Effective date: October 9, 2026

1. Introduction

Pementek is committed to operating payment infrastructure in a manner that is not knowingly used to facilitate money laundering, terrorist financing, sanctions evasion, fraud or other unlawful financial activity.

This Anti-Money Laundering Policy describes the general principles, controls and risk-management practices that Pementek may apply when evaluating merchants, transactions, payment activity, payout activity and other uses of its services.

The nature and level of compliance controls applied in a particular situation may vary according to applicable law, jurisdiction, transaction activity, business model and the level of financial crime risk identified.

2. Scope

This Policy applies to Pementek's payment and payout infrastructure, merchant relationships, transaction processing activities and other services through which financial crime risk may arise.

It may also apply to persons acting on behalf of merchants, beneficial owners, authorized representatives, counterparties and other parties whose information or activity is relevant to a compliance review.

Specific requirements may depend on the country, currency, payment method, transaction type, merchant risk profile and legal or regulatory requirements applicable to the activity.

3. Risk-based approach

Pementek applies a risk-based approach to financial crime compliance. This means that the level of review, verification and monitoring may increase where a merchant, transaction, market or other factor presents greater risk.

Risk assessments may consider factors including:

  • The nature of the merchant's business and business model
  • Countries and markets in which the merchant operates
  • Products and Pementek services being used
  • Payment and payout activity
  • Expected and observed transaction volume
  • Transaction frequency, value and behavioral patterns
  • Ownership and control structure
  • Known fraud or financial crime indicators
  • Sanctions exposure
  • Applicable legal and regulatory requirements

4. Merchant due diligence

Pementek may perform customer or merchant due diligence before or during a business relationship in order to understand who is using its services, the nature of the business and the intended payment activity.

Information requested during due diligence may include:

  • Legal business name and registration information
  • Registered or operating address
  • Information about directors or authorized representatives
  • Beneficial ownership and control information
  • Description of products or services offered
  • Business website or online presence
  • Operating countries and customer markets
  • Expected payment and payout volumes
  • Source of funds or related financial information where appropriate
  • Other supporting compliance documentation

Pementek may use documents, independent information sources, technical checks or other reasonable methods to verify information provided.

5. Beneficial ownership and control

Where appropriate, Pementek may request information needed to understand the natural persons who ultimately own or control a business customer.

Pementek may also request information about directors, shareholders, authorized representatives or other persons who exercise significant control over the merchant.

Complex, opaque or unexplained ownership structures may result in additional review or requests for supporting documentation.

6. Purpose of the business relationship

Pementek may seek to understand why a merchant requires access to the platform and whether the expected use of Pementek is consistent with the merchant's stated business activities.

This assessment may include expected transaction types, average transaction values, volumes, geographic exposure, customer profile and the payment or payout methods expected to be used.

Material inconsistencies between declared business activity and observed transaction activity may result in additional review.

7. Enhanced due diligence

Pementek may apply enhanced due diligence where circumstances indicate a higher level of money laundering, terrorist financing, fraud, sanctions or other financial crime risk.

Enhanced review may be appropriate where, for example:

  • A merchant operates in or has significant exposure to a higher-risk jurisdiction
  • The ownership structure is unusually complex or difficult to verify
  • A relevant individual is identified as a politically exposed person or otherwise presents elevated risk
  • Transaction activity is unusually large, complex or inconsistent with the merchant's known business
  • The stated purpose of transactions is unclear
  • Fraud, sanctions or other financial crime indicators are identified

Enhanced due diligence may include additional documentation, source-of-funds information, ownership verification, explanations concerning transaction activity or increased ongoing monitoring.

8. Politically exposed persons

Where relevant to applicable compliance requirements, Pementek may identify or screen for politically exposed persons, their close associates or certain family members.

The presence of a politically exposed person does not automatically imply unlawful activity. It may, however, require additional risk assessment, verification or enhanced monitoring.

9. Transaction monitoring

Pementek may monitor payment and payout activity for patterns that appear unusual, inconsistent or potentially connected to money laundering, terrorist financing, fraud, sanctions evasion or other prohibited conduct.

Monitoring may consider factors such as:

  • Transaction amount and frequency
  • Unexpected changes in transaction volume
  • Repeated or unusual transaction patterns
  • Countries and markets involved
  • Payment and payout methods
  • Merchant activity compared with its expected profile
  • Technical, account or fraud-related indicators
  • Other information reasonably relevant to financial crime risk

Monitoring controls may combine automated systems, internal rules, risk indicators and human review.

10. Unusual and suspicious activity

Where transaction activity appears unusual or potentially unlawful, Pementek may conduct further review before allowing, continuing or concluding the relevant activity.

Pementek may request additional documentation or explanations from the merchant where reasonably necessary to understand the nature, purpose or source of the activity.

Subject to applicable law, contractual rights and operational requirements, Pementek may:

  • Delay or restrict transaction processing
  • Reject certain activity
  • Restrict merchant functionality
  • Suspend access to services
  • Require additional verification
  • Terminate a business relationship
  • Take other measures reasonably necessary to manage the identified risk

11. Sanctions compliance

Pementek does not permit its services to be knowingly used in violation of applicable economic or financial sanctions, trade restrictions or similar legal measures imposed by competent authorities.

Where appropriate, Pementek may conduct sanctions-related screening of merchants, beneficial owners, representatives or other relevant parties.

Pementek may also review countries, transaction activity and other information where potential sanctions exposure is identified.

Where a confirmed or potential sanctions concern exists, Pementek may restrict or suspend relevant services while the matter is assessed and may take additional action where required by applicable law.

12. Fraud prevention

Fraud prevention forms part of Pementek's broader financial crime risk framework.

Pementek may evaluate transaction information, account activity, technical signals, behavioral patterns, merchant information and other relevant indicators when identifying or responding to suspected fraud.

Where appropriate, fraud-related information may contribute to merchant risk assessments, transaction reviews and decisions concerning continued access to Pementek services.

13. Merchant responsibilities

Merchants are responsible for ensuring that their own business activities, customers, products and use of Pementek comply with applicable laws, regulations and contractual requirements.

Merchants must not knowingly use Pementek to facilitate:

  • Fraudulent or deceptive transactions
  • Unauthorized payment or payout activity
  • Movement of proceeds derived from unlawful conduct
  • Money laundering or terrorist financing
  • Sanctions evasion
  • Transactions intended to conceal the true origin, ownership or destination of funds
  • Transactions intended to evade legal or regulatory restrictions
  • Any other prohibited or unlawful financial activity

Merchants are also responsible for maintaining any customer due diligence, licensing, authorization or financial crime controls required for their own business activities.

14. Information and verification requests

Pementek may request information or documentation reasonably necessary for onboarding, ongoing due diligence, transaction review, sanctions screening, fraud investigation or other compliance purposes.

Merchants are expected to provide complete, accurate and current information within a reasonable period.

Failure or refusal to provide information reasonably required for a compliance review may result in delayed onboarding, restricted services, suspended transaction processing or termination of the business relationship.

15. Ongoing review

Merchant due diligence is not necessarily limited to the initial onboarding process.

Pementek may review or update merchant information during the business relationship when:

  • Business ownership changes
  • Operating markets materially change
  • Transaction activity changes significantly
  • New products or services are introduced
  • New financial crime risks are identified
  • Existing information appears inaccurate or outdated
  • Applicable legal or compliance requirements change

16. Record keeping

Pementek may maintain merchant identification information, verification records, transaction records, risk assessments, compliance reviews and related information where reasonably necessary for legal, regulatory, security, contractual and legitimate business purposes.

Records may include:

  • Merchant onboarding and verification information
  • Beneficial ownership information
  • Transaction and payout records
  • Risk classifications and related decisions
  • Monitoring alerts and investigation records
  • Documentation received during compliance reviews
  • Communications relevant to financial crime investigations

Retention periods may vary depending on applicable law, the nature of the record and Pementek's legal or operational requirements.

17. Protection of compliance information

Compliance, merchant and transaction information may contain confidential or sensitive data and may be protected using appropriate technical and organizational safeguards.

Access to such information may be limited to personnel or service providers who require it for legitimate business, security, legal or compliance purposes.

Additional information concerning Pementek's handling of personal information is available in thePrivacy Policy.

18. Regulatory and law enforcement cooperation

Pementek may cooperate with courts, regulators, law enforcement agencies, financial intelligence authorities, sanctions authorities and other competent governmental bodies where required or permitted by applicable law.

This cooperation may include responding to lawful requests for information, preserving records, implementing legally required restrictions or complying with applicable reporting obligations.

Pementek may be legally restricted from notifying a merchant or other party about certain investigations, reports or government requests.

19. Service restriction, suspension and termination

Pementek may restrict, suspend, refuse or terminate access to its services where financial crime risk, suspected unlawful activity, sanctions exposure, fraud concerns, failure to cooperate with compliance reviews or other legal requirements make such action appropriate.

Action may be taken without prior notice where notice would be prohibited by law, could compromise an investigation or would otherwise create material compliance or security risk.

Additional rights concerning suspension and termination may be described in Pementek'sTerms of Serviceor applicable commercial agreements.

20. Internal controls and training

Pementek may maintain internal procedures, operational controls and training appropriate to the nature and scale of its business and the financial crime risks associated with its services.

Relevant personnel may receive guidance concerning topics such as:

  • Money laundering and terrorist financing indicators
  • Merchant due diligence
  • Beneficial ownership
  • Sanctions risk
  • Transaction monitoring
  • Fraud indicators
  • Internal escalation procedures
  • Record keeping and confidentiality

Pementek may review its internal controls as services, regulatory expectations, supported markets and financial crime risks evolve.

21. Third-party services and information

Pementek may use reputable third-party service providers, databases or information sources to support identity verification, business verification, sanctions screening, fraud detection, risk assessment or other compliance functions.

Use of third-party services does not remove Pementek's responsibility to manage its own compliance decisions in a manner appropriate to the services it provides.

22. Policy review and updates

Pementek may periodically review and update this Policy to reflect changes in its services, supported markets, risk environment, operational practices or applicable legal and regulatory requirements.

The effective date displayed at the top of this page identifies the current published version.

Material changes may be communicated through Pementek's website or other appropriate merchant communication channels.

23. Contact

Questions concerning this Anti-Money Laundering Policy, merchant compliance reviews or other financial crime matters may be submitted through Pementek's official contact channels.

Email:pementek@protonmail.com

Telegram:@pementek

For compliance matters that may contain confidential, sensitive or personally identifiable information, email should be used instead of Telegram.

Additional contact information is available on theContact page.