Terms of Service
Last Updated: [2026-01-01]
These Terms of Service (“Terms”) govern your access to and use of the services provided under the PengoPay brand (the “Services”).PengoPay is operated by Pengo Technologies Ltd, a company incorporated in Abu Dhabi Global Market (ADGM) (“Pengo”, “we”, “us”, or “our”).By accessing or using the Services, you confirm that you have read, understood, and agreed to be bound by these Terms.
PengoPay provides stablecoin payment infrastructure and custody-related technical services designed for business users.The Services may include, but are not limited to:
Stablecoin payment acceptance tools
Managed wallet infrastructure
Transaction monitoring and technical controls
Integration with licensed third-party fiat on-ramp and off-ramp providers
PengoPay does not:
provide fiat currency services;
operate as an exchange, broker, or dealer;
engage in OTC trading or price quotation;
act as a bank or licensed financial institution.
Pengo Technologies Ltd is registered as a Foreign Money Services Business (FMSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and complies with applicable Canadian anti-money laundering (AML) and counter-terrorist financing (CTF) requirements.PengoPay does not provide regulated financial services in the United Arab Emirates or any other jurisdiction unless explicitly stated.
PengoPay provides custody-related technical services and managed wallet infrastructure only.
Digital assets are held using secure wallet architectures supported by technical safeguards and authorization mechanisms.
PengoPay does not independently control or unilaterally dispose of user assets.
Users retain responsibility for their digital assets and transaction decisions.
PengoPay is not a licensed digital asset custodian or custody bank.
The Services are intended solely for business users who have the legal capacity to enter into binding agreements.By using the Services, you represent and warrant that:
you are using the Services for lawful business purposes;
you are not located in, incorporated in, or otherwise operating from any Restricted Jurisdiction (as defined below);
your use of the Services complies with all applicable laws and regulations.
5.1 Prohibited Countries and Regions
PengoPay does not provide Services to residents or entities located in, incorporated in, or operating from the following jurisdictions (“Restricted Jurisdictions”):
Singapore
United States of America
Mainland China
Japan
South Korea
Hong Kong
United Kingdom
Any jurisdiction subject to comprehensive economic or trade sanctions, including but not limited to: Iran, North Korea, Syria, Cuba, and any other jurisdiction designated under applicable sanctions laws.
PengoPay does not actively market, solicit, or provide Services in any Restricted Jurisdiction.
5.2 User Responsibility
Users are solely responsible for determining whether their access to or use of the Services is permitted under applicable local laws.PengoPay makes no representation that the Services are appropriate or available for use in any particular jurisdiction.
PengoPay does not currently conduct full customer identity verification (KYC).Users acknowledge and agree that:
limited or no KYC does not imply regulatory approval in any jurisdiction;
PengoPay may implement reasonable compliance measures, including self-declarations or geographic controls, where necessary.
Fiat on-ramp and off-ramp services are provided exclusively by independent third-party partners that are licensed and regulated in their respective jurisdictions.PengoPay is not responsible for the acts, omissions, or compliance of any third-party service provider.
To the maximum extent permitted by law, PengoPay shall not be liable for any indirect, incidental, consequential, or special damages arising out of or related to the use of the Services.Users assume full responsibility for all risks associated with digital asset transactions.
PengoPay reserves the right to suspend or terminate access to the Services at any time, including where continued access may expose PengoPay to regulatory, legal, or compliance risks.
These Terms shall be governed by and construed in accordance with the laws of Abu Dhabi Global Market (ADGM), without regard to conflict of law principles.
Nothing in these Terms constitutes legal, financial, or investment advice.
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