Compliance and Risk Management
Our Commitment
At PinguinoPay we understand that trust, transparency and security are fundamental to building solid and sustainable financial relationships.
For this reason, we maintain compliance policies and procedures aimed at protecting the integrity of our operations, preventing fraud, money laundering, terrorist financing, evasion of international sanctions and other illicit activities.
Our compliance program adopts a risk-based approach and integrates Know Your Customer (KYC), Know Your Business (KYB), Know Your Transaction (KYT) procedures, verification of the source of funds and continuous monitoring of operations.
As part of our multi-rail infrastructure, we incorporate assessment and traceability mechanisms for digital assets, including the analysis of blockchain wallet addresses and the identification of risks associated with transactions. These controls may be implemented directly or through specialized providers and financial partners participating in our operational infrastructure.
We work under principles of due diligence, proportionality and continuous improvement, adapting our procedures to the nature of each operation, the jurisdictions involved and the identified risks.
Our commitment is to provide a reliable, transparent and responsible technological and operational infrastructure, allowing our clients to manage national and international payments and disbursements with security, efficiency and continuity.
PinguinoPay is a technological solution designed to facilitate the receipt, administration, and disbursement of funds for individuals and companies operating in national and international markets.
We work with duly authorized financial institutions, payment processors, and specialized providers, as applicable to each service and jurisdiction.
PinguinoPay is not a banking institution, a SEDPE, or a financial intermediation entity. Our function consists of providing technological and operational infrastructure that facilitates the efficient management of payments and disbursements.
Our Operating Model
PinguinoPay provides a technology platform that facilitates the administration, collection, and disbursement of funds for individuals and businesses operating in domestic and international markets.
Depending on the contracted service, our clients can use the platform to receive payments, manage balances, coordinate disbursements to beneficiaries, or administer operations related to independent contractors, vendors, collaborators, and internationally distributed teams.
PinguinoPay facilitates the coordination of payments and disbursements for businesses, independent contractors, vendors, and internationally distributed teams. Depending on the nature of each transaction, funds may be processed through financial institutions, payment processors, disbursement partners, and other specialized providers participating in the execution of the contracted services.
PinguinoPay does not collect funds from the public nor does it conduct activities exclusively reserved for regulated financial institutions. Any financial, payment, custody, or processing services that may be required to complete specific transactions are provided by specialized third parties that are duly authorized within their respective jurisdictions.
As part of our operating model, we apply verification procedures to clients, businesses, and, where applicable, ultimate beneficial owners of the funds. These verifications may include identity checks, document verification, risk analysis, and controls related to fraud prevention and regulatory compliance.
Additionally, we maintain policies designed to understand the nature of the transactions conducted through our platform, including our clients' economic activity, the purpose of the business relationship, and the source of the funds involved.
Our goal is to provide an efficient, transparent, and responsible technological infrastructure that allows our clients to manage payments and disbursements securely while we fulfill our contractual and risk management obligations. The scope of services and contractual responsibilities are detailed in our Terms and Conditions.
Our Partners and Suppliers
For the provision of our services, we collaborate with financial institutions, payment processors, technology providers, disbursement partners, and other specialized providers located in different jurisdictions.
These third parties perform specific functions within PinguinoPay's operating ecosystem and may participate in processes related to payments, disbursements, validations, risk management, regulatory compliance, and technological support.
We carefully select our providers and strategic partners based on operational, commercial, technological, and compliance criteria, seeking to maintain high standards of reliability, security, and service continuity.
Know Your Customer (KYC)
As part of our compliance program, we verify the identity of the individuals who use our services.
Depending on the level of risk associated with each business relationship, we may request additional information intended to validate identity, economic activity, source of funds, and other relevant information for compliance with our legal and contractual obligations.
The information provided by our users must be complete, accurate, and kept up to date.
Know Your Business (KYB)
Companies that use our services are subject to corporate validation processes.
These procedures may include the verification of:
Legal existence of the entity.
Authorized legal representatives.
Ultimate beneficial owners (UBO).
Economic activity carried out.
Corporate structure.
Tax and regulatory information.
The depth of these verifications will depend on the risk profile of each client and the nature of the operations carried out.
Know Your Transaction (KYT)
As part of our compliance and risk management program, PinguinoPay incorporates digital asset transaction analysis and monitoring procedures (Know Your Transaction – KYT), aimed at strengthening the traceability, transparency, and integrity of operations.
These procedures include the evaluation of digital wallet addresses used for sending funds, using specialized blockchain analysis tools and risk identification mechanisms associated with illicit activities, sanctioned addresses, and unusual transactional patterns.
The KYT assessment may include:
Verification and analysis of source wallet addresses.
Evaluation of exposure to addresses or entities identified as high-risk.
Identification of potential links to illicit activities or international sanctions lists.
Traceability and behavior analysis of transactions on blockchain networks.
Application of enhanced review measures when relevant risk indicators are identified.
These controls are implemented directly or in coordination with specialized providers and financial partners participating in our operational infrastructure.
PinguinoPay may request additional information, perform extra verifications, or restrict certain operations when the results of these analyses indicate risks that require a more detailed evaluation.
The incorporation of KYT controls complements our Know Your Customer (KYC), Know Your Business (KYB), and prevention of money laundering and terrorist financing (AML/CFT) procedures, strengthening our comprehensive compliance approach in traditional and digital asset financial operations.
Risk-Based Approach
We apply a risk-based assessment model to determine the level of review and monitoring required for each client.
Among the factors considered are:
Economic activity.
Jurisdictions involved.
Volume and frequency of transactions.
Corporate structure.
Channels used.
History of the business relationship.
This approach allows us to allocate resources efficiently and apply measures proportional to the identified risk.
Verification of Origin of Funds
In order to maintain a safe and transparent environment, we may request documentation to validate the legitimate source of funds processed through our platform.
Among other documents, we may require:
Invoices.
Contracts.
Financial statements.
Accounting certifications.
Business activity support documents.
Tax documentation.
These verifications are part of our standard risk management controls and may be conducted during the onboarding process or at any time during the business relationship.
Monitoring of Activities and Transactions
We implement monitoring procedures designed to identify unusual activities, operational inconsistencies, or behaviors that may represent risks to our clients, business partners, or the integrity of our platform.
Depending on the circumstances, we may request additional information, perform complementary reviews, or temporarily restrict certain operations while the corresponding analysis is completed.
Our goal is to ensure that the processed operations are consistent with the activity declared by each client and with the purpose of the established business relationship.
International Sanctions and Politically Exposed Persons
As part of our compliance controls, we may perform validations against international sanctions lists, restrictive lists, and other relevant public information sources.
Likewise, we may apply enhanced due diligence measures when we identify relationships with Politically Exposed Persons (PEPs), high-risk beneficial owners, or other categories that require a more detailed analysis.
Alert Management and Enhanced Due Diligence
PinguinoPay incorporates procedures for reviewing and escalating alerts related to clients, counterparties, and transactions that present unusual or high risk indicators.
Depending on the nature of the alert, we may apply enhanced due diligence measures, request complementary documentation, verify transactional information, or coordinate reviews with the financial providers involved.
The measures adopted will be proportional to the identified risk and may include the postponement, rejection, or restriction of certain transactions, in accordance with our internal policies and applicable obligations.
These procedures contribute to preserving the integrity of our infrastructure and strengthening the prevention of illicit financial activities.
Fraud Prevention
We maintain controls designed to prevent, detect, and investigate fraudulent activities that could affect our clients, business partners, or the platform.
These controls may include document validations, transactional behavior analysis, manual reviews, and other reasonable risk mitigation measures.
Due Diligence of Counterparties and Allies
PinguinoPay applies due diligence criteria in the selection, onboarding, and evaluation of commercial counterparties, financial institutions, payment service providers, and technological allies participating in its operational infrastructure.
These evaluations may include corporate identification, the review of applicable authorizations or registrations, jurisdictions of operation, compliance mechanisms, operational capacity, and relevant backgrounds of each counterparty.
Our approach seeks to establish relationships with organizations that maintain appropriate standards of transparency, security, reliability, and risk management, promoting the integrity and continuity of our services.
Business Continuity and Resilience
PinguinoPay incorporates principles of operational continuity and technological resilience into the design and administration of its payment infrastructure.
Our multi-rail model allows the integration of different financial institutions, payment providers, and technology partners, facilitating the diversification of channels and the reduction of operational dependencies.
We apply monitoring procedures, provider evaluations, and contingency management aimed at preserving the stability, security, and availability of our services.
This approach is part of our commitment to a reliable, adaptable infrastructure prepared to respond to the changing needs of our clients and business partners.
Prohibited Activities
PinguinoPay does not provide services to persons or entities involved in illicit activities or activities prohibited by applicable law.
Among others, activities related to the following are restricted:
Money laundering.
Terrorist financing.
Financial fraud.
Identity theft.
Corruption.
Evasion of international sanctions.
Operations intended to conceal the origin of funds.
We reserve the right to refuse, suspend, or terminate business relationships when we identify risks that are incompatible with our internal policies.
Record Retention
We maintain records related to our clients, operations, and compliance processes for the periods required by applicable legislation and our internal policies.
These records may be used for auditing, regulatory compliance, risk management, and addressing requests from competent authorities.
Information Protection
The information provided by our clients is processed in accordance with our privacy policies and information security policies.
We implement administrative, technical, and organizational measures aimed at protecting the confidentiality, integrity, and availability of the data under our responsibility.
Continuous Improvement
Our compliance program is periodically reviewed and updated to adapt to regulatory changes, industry best practices, and search for new risk typologies.
Responsible risk management is a fundamental component of our commitment to clients, business partners, and financial entities.
Compliance Contact
For inquiries related to compliance, document validation, or due diligence processes, you can contact us at:
compliance@pinguinopay.com
or through the official support channels published on our website.
Compliance Government
The PinguinoPay compliance program is periodically reviewed by the company's management and may be updated to reflect regulatory, operational, or risk changes.
