PesaNet
PesaNetLegal

Regulatory Document

Regulatory Compliance

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

PesaNet, Inc. is committed to operating in full compliance with applicable financial services laws and regulations. This page provides an overview of our licences, regulatory registrations, standards adherence, and consumer protection disclosures.

1. Regulatory Registration — FinCEN

PesaNet, Inc. is registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury.

  • FinCEN BSA ID (Registration Number): 31000332677999
  • Submission Tracking Number: MRX26-00006351
  • MSB Type: Money Transmitter; Dealer in Foreign Exchange
  • Registration Status: Active
  • Filing Date: June 10, 2026
  • Acceptance Date: June 12, 2026

FinCEN registration can be verified at the FinCEN MSB Registrant Search.

2. State Money Transmitter Activity

PesaNet does not currently hold state money transmitter licences. US money transmission operates through sponsor-bank partnerships under the agent-of-the-bank model. State-level licensure analysis is in progress and direct filings will follow as the sponsor-bank arrangement is finalised and commercial volume scales.

  • NMLS Company ID: 2855902 — PesaNet's NMLS company record is established. No state MTL applications have been filed at this time.
  • Montana: No state-level licensure required; operations covered under federal FinCEN MSB registration (§1).

PesaNet's home-jurisdiction registration is the FinCEN MSB filing in §1 above. Customers should refer to our Terms of Service for current jurisdictional availability.

3. Card Issuing — Stripe Issuing

PesaNet's virtual debit cards are issued through Stripe Issuing, a regulated card programme manager. Cards operate on the Visa network.

  • Cards are issued pursuant to Stripe's issuing bank licence and Visa programme rules.
  • Cardholders are subject to Stripe Issuing's Cardholder Terms in addition to these Terms.
  • PCI DSS compliance: PesaNet's card data handling meets PCI DSS Level 1 requirements. Raw card numbers (PANs) and CVVs are never stored by PesaNet — all sensitive card data is tokenised and held exclusively by Stripe.

4. Bank Account Linking — Plaid

Bank account linking and ACH transfer initiation are facilitated through Plaid, Inc., a licensed data aggregator and payment initiator. Plaid is subject to applicable federal and state financial data regulations.

  • ACH transfers are processed through the Automated Clearing House network under NACHA rules.
  • PesaNet does not have direct access to your bank login credentials — all bank authentication is handled by Stripe Financial Connections.

5. Peer Lending Regulatory Disclosure (Future Feature — Not Currently Offered)

Peer lending is not currently offered on PesaNet. The disclosures below describe how peer lending would operate if and when it is launched in supported markets. PesaNet will not relaunch peer lending without applicable regulatory approvals, sponsor-bank arrangements, and state-by-state consumer disclosure templates (including TILA disclosures and usury cap compliance) in place.

  • If launched, PesaNet would be not a lender and would not participate in lending decisions.
  • Peer loans would be not FDIC-insured and would carry risk of principal loss.
  • Interest rates would be set by individual lenders. Lenders would be responsible for ensuring their lending activity complies with applicable state usury laws; PesaNet would clamp rates at apply-time to the borrower's state cap.
  • PesaNet would not provide investment advice. Past performance of peer lending on the platform would not guarantee future returns.
  • Borrowers in certain states would be subject to additional disclosures required by state consumer lending laws. PesaNet would provide these disclosures at the point of loan application.

6. Consumer Protection

6.1 Error Resolution

For unauthorised or erroneous transactions on your wallet or virtual card, contact us within 60 days at disputes@pesanet.app. We will investigate and respond within 10 business days (or 45 days for complex cases, with provisional credit where applicable) in accordance with the Electronic Fund Transfer Act (EFTA) and Regulation E.

6.2 Funds Safety

Customer wallet balances are held in segregated accounts at FDIC-insured financial institutions. PesaNet does not commingle customer funds with operating funds. While PesaNet itself is not a bank and wallet balances are not directly FDIC-insured in your name, the underlying custodial bank accounts are insured. Consult our Terms of Service for full details.

6.3 Complaints

If you have a complaint about PesaNet's services:

  • In-app: Help → Contact Support
  • Email: complaints@pesanet.app
  • Regulators: You may also file a complaint with the Consumer Financial Protection Bureau (CFPB) at consumerfinance.gov or your state's financial regulator.

7. Anti-Bribery and Anti-Corruption

PesaNet maintains a zero-tolerance policy for bribery and corruption in all forms. Our employees, contractors, and agents are prohibited from offering, giving, requesting, or accepting any bribe, kickback, or improper payment to influence business decisions. This policy applies globally and covers both public officials and private sector interactions, in compliance with the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010.

8. Data Protection Compliance

  • GDPR: PesaNet complies with the General Data Protection Regulation for EU/EEA users. See our Privacy Policy.
  • CCPA/CPRA: PesaNet complies with California privacy law for California residents.
  • GLBA: PesaNet complies with the Gramm-Leach-Bliley Act safeguards rule for financial data protection.

9. Accessibility

PesaNet strives to make its Services accessible to all users, including those with disabilities. We aim for WCAG 2.1 Level AA conformance in our mobile application and website. Report accessibility issues to accessibility@pesanet.app.

10. Regulatory Contact