PesaNet

Legal Document

Acceptable Use Policy

Effective Date: January 1, 2025Last Updated: March 1, 2026Version: 2.0

This Acceptable Use Policy ("AUP") governs the use of PesaNet's mobile application, website, and financial services ("Services"). It supplements our Terms of Service and applies to all users, including individuals, PesaNet Agents, and businesses.

Violations of this AUP may result in account suspension, account closure, withholding of funds, and referral to law enforcement or financial regulators.

1. Permitted Uses

PesaNet is designed for lawful personal and small business financial activities, including:

  • Sending and receiving money between friends, family, and verified contacts
  • Paying for goods and services from legitimate merchants using your virtual card
  • Depositing and withdrawing funds to and from personal bank accounts
  • Participating in peer lending as a private individual lender or borrower
  • Using PesaNet Agents to conduct cash-in and cash-out transactions
  • Requesting payment for personal services rendered (e.g., freelance work, tutoring)
  • Managing a small business's payments through a verified business account

2. Absolutely Prohibited Activities

The following activities are strictly prohibited and will result in immediate account termination and reporting to relevant authorities:

2.1 Financial Crimes

  • Money laundering: Using PesaNet to layer, place, or integrate proceeds of criminal activity
  • Terrorist financing: Funding or facilitating terrorism or terrorist organisations
  • Structuring: Breaking up transactions to avoid Currency Transaction Report (CTR) filing thresholds
  • Sanctions evasion: Transacting with OFAC SDN-listed individuals or entities, or circumventing applicable sanctions
  • Fraud: Using PesaNet to commit identity fraud, payment fraud, or any other form of financial fraud
  • Unauthorised transactions: Initiating transactions from accounts you do not own or are not authorised to use

2.2 Illegal Goods and Services

  • Purchase, sale, or distribution of illegal drugs, narcotics, or controlled substances
  • Purchase, sale, or distribution of illegal weapons, explosives, or ammunition
  • Purchase or sale of counterfeit goods, forged documents, or fraudulent credentials
  • Distribution of child sexual abuse material (CSAM) or any content that exploits minors
  • Human trafficking or facilitating forced labour
  • Payments for escort services or prostitution in jurisdictions where illegal

2.3 Schemes and Scams

  • Operating or participating in Ponzi schemes, pyramid schemes, or "get rich quick" scams
  • Advance fee fraud (e.g., "419 scams")
  • Phishing, smishing, or any form of social engineering targeting PesaNet users
  • Selling or purchasing PesaNet accounts
  • Creating fake PesaNet profiles to deceive other users

2.4 Gambling

  • Unlicensed online gambling or gambling in jurisdictions where it is prohibited
  • Using PesaNet as a payment method for gambling platforms that are not licensed in the user's jurisdiction

2.5 Platform Abuse

  • Attempting to reverse-engineer, hack, or penetration-test PesaNet systems without written authorisation
  • Interfering with the operation of PesaNet's infrastructure or other users' accounts
  • Automated scraping of PesaNet data
  • Creating accounts using false identity information or others' identities
  • Bypassing security controls including device fingerprint validation, PIN requirements, or KYC processes
  • Sending unsolicited money requests to users you do not know

3. Restricted Activities (Require Pre-Approval)

The following activities are restricted and require prior written approval from PesaNet's Compliance team before use:

  • High-volume peer transfers: Regular transfers exceeding $50,000/month for non-business accounts
  • Charity and crowdfunding: Collecting donations or crowdfunding through PesaNet
  • Business payroll: Using personal PesaNet accounts to pay employees
  • Cryptocurrency exchanges: Using PesaNet as a funding source for crypto exchanges (subject to review)
  • International transfers: Transfers to certain high-risk jurisdictions require enhanced verification

To request approval, contact compliance@pesanet.app.

4. Agent-Specific Rules

PesaNet Agents are subject to additional rules under the Agent Terms of Service, including:

  • Conducting KYC identity checks on all customers per PesaNet's prescribed process
  • Refusing to process transactions for individuals who cannot be verified
  • Not processing transactions that appear to be structuring or money laundering
  • Not charging fees above PesaNet's published agent fee schedule
  • Not conducting transactions outside of authorised agent location(s)
  • Maintaining a transaction log accessible to PesaNet on request

5. Reporting Violations

If you suspect another user, agent, or third party is violating this AUP, please report it to us:

All reports are reviewed by our Trust & Safety team. We may contact you for additional information. We do not disclose the identity of reporters without your consent except as required by law.

6. Consequences of Violations

Depending on the severity and nature of the violation, PesaNet may:

  • Issue a warning and require corrective action
  • Temporarily restrict account features
  • Suspend the account pending investigation
  • Permanently close the account and ban the user from creating new accounts
  • Hold funds for up to 180 days pending compliance review or legal hold
  • File a Suspicious Activity Report (SAR) with FinCEN
  • Report the matter to law enforcement, the FBI, or relevant financial regulators
  • Pursue civil legal action to recover damages

7. Changes to This Policy

PesaNet may update this AUP at any time. Significant changes will be communicated via in-app notification. Continued use of the Services constitutes acceptance of the updated AUP.

8. Contact