PentrraWallet
PentrraWallet PentrraWallet is a technology platform and an online services company that provides its users with a range of digital services.
PentrraWallet is not a bank. PentrraWallet does not provide traditional banking services and does not present itself as a banking institution.
As part of its activities and business relationships, PentrraWallet applies measures designed to prevent and detect risks related in particular to money laundering, terrorist financing, fraud, identity theft, sanctions circumvention, and other illicit activities.
This Policy sets out the compliance principles and procedures applied by PentrraWallet.
PentrraWallet adopts a risk-based approach and reserves the right to adjust the level of control applied to each user, account, transaction, or situation.
No user may use PentrraWallet's services without first completing and passing the applicable identity verification procedure.
This obligation applies in particular to individual users as well as to businesses, developers, and other legal entities where applicable.
During the verification process, PentrraWallet may collect and verify, in particular:
Identity checks may be carried out automatically using specialized technological systems.
Where the information or documents provided do not sufficiently confirm the user's identity, verification may be declined.
The user may be permitted to resubmit their documents in accordance with the procedures available on the platform.
A user's initial verification does not constitute a final and permanent validation.
PentrraWallet may request additional information, documents, or supporting evidence at any time, including where the user has already been verified.
Depending on the situation, PentrraWallet may in particular request:
The user is required to provide the requested items within the timeframe communicated by PentrraWallet.
Businesses and legal entities may be subject to a KYB (Know Your Business) procedure.
PentrraWallet may in particular verify:
Any person directly or indirectly holding 25% or more of the ownership or control of a business may be considered a beneficial owner for the purposes of PentrraWallet's verification procedures.
PentrraWallet may request additional documents where the ownership or control structure is not sufficiently clear.
PentrraWallet applies a risk-based approach.
The level of control may take into account, in particular:
A high risk level may result in additional checks, temporary restrictions, a request for additional documents, or enhanced monitoring.
PentrraWallet may identify and monitor Politically Exposed Persons (PEPs) as well as, where relevant, their relatives and close associates.
PEP status does not automatically constitute grounds for refusal.
However, where a user presents PEP exposure, PentrraWallet may apply enhanced control measures and conduct closer monitoring of the account and the relevant transactions.
PentrraWallet carries out, or may carry out, checks designed to identify persons, businesses, or other entities subject to applicable sanctions or restrictions.
These checks may take into account, among other things, sanctions lists and measures published by the competent authorities in the United Kingdom, the United States, the European Union, the United Nations, and any other authority relevant to PentrraWallet's activities.
PentrraWallet does not rely on a single sanctions list as its exclusive reference and may carry out additional checks when necessary.
Where a check produces a potential match, PentrraWallet may temporarily suspend the account or the relevant transactions in order to carry out further verification.
Where a match with a sanctioned person or entity is confirmed, PentrraWallet may block or restrict the relevant services and terminate the relationship with the user, in accordance with applicable legal and regulatory requirements.
PentrraWallet may provide its services to users located in different countries and territories around the world, subject to applicable restrictions.
The fact that a user is located in a jurisdiction considered to present a higher level of risk does not automatically mean their account will be refused.
However, PentrraWallet may apply enhanced vigilance measures where a jurisdiction or activity presents a higher level of risk.
Persons, businesses, or territories subject to applicable sanctions or restrictions may be excluded from using PentrraWallet's services.
PentrraWallet may carry out ongoing monitoring of accounts and activities to identify unusual behavior or behavior presenting a compliance risk.
This monitoring may in particular cover:
A transaction may be temporarily suspended, blocked, or subject to verification where it presents a risk or an anomaly requiring review.
PentrraWallet may ask any user to provide information to help understand the source of funds, or, where necessary, the source of wealth.
Depending on the profile and level of risk, PentrraWallet may request supporting evidence to confirm the information provided.
The user must provide accurate and verifiable information.
The inability, refusal, or unjustified reluctance to provide the requested information may constitute a compliance risk factor and result in an account restriction or suspension.
Where the level of risk requires it, PentrraWallet may apply Enhanced Due Diligence (EDD).
This procedure may in particular include:
The duration and scope of these checks may vary depending on the situation.
PentrraWallet may temporarily suspend an account or restrict certain features where a compliance review is necessary.
This measure may in particular be taken where it is necessary to:
The suspension may remain in effect until the necessary checks have been satisfactorily completed.
Where an activity or transaction presents characteristics that may raise a risk of money laundering, terrorist financing, fraud, or any other illicit activity, PentrraWallet may carry out an in-depth review.
Depending on the circumstances, PentrraWallet may:
Where the law requires or permits it, PentrraWallet may share relevant information with the competent authorities, bodies, or partners.
PentrraWallet is not required to disclose to the user all information relating to its internal detection, monitoring, or risk assessment systems.
In certain circumstances, PentrraWallet may also be legally prevented from disclosing the exact nature, existence, or details of a check, investigation, or report.
PentrraWallet may therefore limit the information disclosed to the user where necessary to comply with its legal, regulatory, or compliance obligations.
The user must cooperate with PentrraWallet's compliance procedures.
Refusal to provide the requested documents or information, the provision of false or inconsistent information, or any attempt to circumvent compliance checks may result in:
The timeframe given to the user to provide the requested information will be communicated directly by PentrraWallet depending on the situation.
PentrraWallet may terminate the relationship with a user where a compliance risk cannot be reasonably resolved or where a violation of applicable requirements is identified.
This may occur, in particular, in the event of:
Any decision concerning any funds remaining in the account will be made in accordance with applicable laws, compliance requirements, applicable procedures, and, where necessary, the requirements of relevant providers.
Any attempt at fraud, identity theft, manipulation of verification procedures, or creation of multiple accounts in order to circumvent PentrraWallet's controls is strictly prohibited.
PentrraWallet may suspend or close all accounts it believes are linked to the same person where necessary to prevent fraud or the circumvention of compliance measures.
PentrraWallet may retain the information and documents necessary for its compliance procedures, including information relating to identity, businesses, verifications, transactions, and checks carried out.
The retention period and processing arrangements for this information are defined in accordance with applicable legal and regulatory requirements as well as PentrraWallet's Privacy Policy.
PentrraWallet does not retain data beyond the period authorized or required under the applicable framework.
PentrraWallet may cooperate with authorities, competent bodies, and other legally authorized parties where such cooperation is required or permitted by law.
This cooperation may relate in particular to:
PentrraWallet may provide legally required information without the user being able to object to such disclosure where it is required by law.
Compliance procedures may result in the refusal, suspension, limitation, or termination of certain services.
PentrraWallet prioritizes the security, compliance, and integrity of its platform over the continuity of a service where a serious risk is identified.
No user may demand the continuation of a service where a restriction is necessary to meet a legal, regulatory, security, or compliance obligation.
Compliance procedures must be handled in a professional and respectful manner.
Threats, intimidation, insults, harassment, or abusive pressure directed at PentrraWallet, its teams, or its representatives may constitute a violation of the Terms and Conditions of Use.
Such conduct may result in the suspension or closure of the account in accordance with applicable rules.
No pressure exerted on PentrraWallet will allow a compliance procedure to be circumvented or a restriction to be lifted.
This Policy must be read together with:
In the event of a contradiction between these documents, applicable mandatory legal and regulatory provisions shall prevail.
PentrraWallet may modify this Policy where necessary to reflect, in particular, changes to its activities, its internal procedures, identified risks, or the applicable legal and regulatory framework.
The most recent version of this Policy is published through PentrraWallet's official channels.
For any question relating to this Policy or to PentrraWallet's compliance procedures:
Email: support@pentrrawallet.com
PentrraWallet may ask the user to provide the necessary information before responding to certain requests relating to their account.
This Policy describes the compliance measures implemented by PentrraWallet as part of its activities and does not constitute a statement that PentrraWallet is, on its own, a banking institution or a regulated financial institution.