Tentunit Business — AML & Fraud Prevention Policy
Version 1.0 (Draft — pending legal review) · Effective Date: July 11, 2026 · Applies to: Tentunit Business
This page is informational. It explains, but does not override, the Payments & Rent Collection Terms, which control.
1. Overview & Commitment
This page explains how Tentunit Business detects and responds to fraud, money laundering, and payment abuse. The binding rules — including prohibited payment activity, holds, and cooperation duties — are in the Payments & Rent Collection Terms, particularly Sections 4, 7, 8, 15, and 16.
1.1 Our Commitment
Tentunit, Inc. (“Tentunit,” “we,” “us”) is committed to keeping Tentunit Business free of financial crime. We comply with applicable anti-money-laundering (“AML”) laws, U.S. OFAC sanctions, and EU and UK sanctions regimes, and we operate on infrastructure provided by Stripe, whose regulated compliance programs apply to every payment. Rent is among the largest recurring payments in a tenant’s life, and landlords depend on those funds arriving intact; fraud prevention is how we keep that promise for both sides.
1.2 Scope
This policy covers fraud detection, suspicious activity handling, payment abuse controls, account freezes, and cooperation with processors and authorities across Tentunit Business in the US, EU, and UK. It applies to landlords, property managers, their authorized users, and — where payment behavior is concerned — tenants paying through the platform.
1.3 Related Documents
Identity verification, which is the front door of this program, is described in the KYC & Identity Verification Policy. Payout mechanics affected by risk reviews are described in the Payout & Settlement Policy. Disputes and chargebacks are covered in the Chargeback & Dispute Handling Policy. The binding obligations behind all of these pages are in the Payments & Rent Collection Terms and the Business Terms of Service.
2. Fraud Detection Principles
We do not publish the precise thresholds and rules our systems use — doing so would hand fraudsters a map. This section instead describes the principles behind our detection program in qualitative terms.
2.1 Risk-Based Approach
Our controls are proportionate to risk. A small landlord collecting predictable monthly rent from long-standing tenants sees very little friction; an account with sudden volume spikes, high-risk indicators, or inconsistent verification data receives closer scrutiny, and may face enhanced due diligence under Section 4.2 of the Payments & Rent Collection Terms. This approach mirrors the expectations of AML regulators in the US, EU, and UK.
2.2 Layered Controls
No single check catches everything, so we layer them: identity verification at onboarding, transaction screening at payment time, payout-level review before funds leave the platform, and periodic account-level review afterward. Stripe’s risk tooling operates alongside Tentunit’s own platform-level controls, so a payment passes through multiple independent layers before it settles.
2.3 Velocity and Anomaly Monitoring
We monitor for patterns that deviate from an account’s established behavior — an unusual burst of new tenants, charges inconsistent with the properties on file, rapid changes to payout bank details, or amounts that break sharply from historical rent levels. Anomalies do not automatically mean wrongdoing; they mean a review takes a closer look before funds move.
2.4 Device and Session Signals
Signals about the devices, sessions, and access patterns used to operate an account — such as sign-ins from unexpected locations or credential-stuffing patterns — feed into our risk assessment, helping us distinguish a legitimate landlord traveling abroad from an account takeover in progress. These signals are processed as described in the Tentunit Privacy Policy.
3. Suspicious Activity Handling
When something looks wrong, we investigate before money moves. This section describes what that looks like from your side of the dashboard.
3.1 Internal Review
Flagged activity is routed to internal review, which may involve automated scoring, manual investigation by our risk team, and consultation with Stripe. During review we may ask you questions about your identity, ownership, properties, tenants, or the source or purpose of funds. Under Section 4.3 of the Payments & Rent Collection Terms, you must respond promptly and truthfully; failure to respond within the time we reasonably specify may itself result in holds or suspension.
3.2 Payout Holds During Review
We or Stripe may delay or hold payouts while a review is underway, as permitted by Sections 4.5 and 7.2 of the Payments & Rent Collection Terms. Where legally permitted, we will notify you of a compliance-related hold within 5 business days. Held funds are released promptly once the basis for the hold is resolved, subject to any reserve established under Section 8 of the Payments & Rent Collection Terms. Tentunit does not pay interest or compensation on funds held during a good-faith review.
3.3 Reporting to Regulators and Processors
Where the law requires or permits, we may file reports with regulators and law enforcement — including suspicious activity reports under applicable AML regimes — and share information with Stripe and card networks, without notice to you. This is a legal obligation, not a discretionary choice.
3.4 No Tipping-Off
AML laws in the US, EU, and UK prohibit “tipping off” — telling a person that they are the subject of a suspicious activity report or related investigation. This means that in some cases we cannot tell you why a hold or review is happening, or that a report has been filed. Where notification is withheld, it is because disclosure is prohibited by law, would compromise an investigation, or is restricted by a regulator, card network, or Stripe.
4. Payment Abuse Controls
Tentunit Business exists to move rent, deposits, and lease-related charges — nothing else. This section explains the specific abuse patterns we block, which are binding prohibitions under Section 15 of the Payments & Rent Collection Terms.
4.1 No Unrelated Money Movement
You must not use the platform to move money for purposes unrelated to bona fide rent, deposits, or lease-related charges for properties you own or manage. Tentunit is a limited payment collection agent for rent — it is not a general money transmission service, and using it as one violates the Payments & Rent Collection Terms and potentially money transmission law.
4.2 No Self-Dealing Rent Payments
Paying “rent” to yourself — charging a card you control against a property you own to cycle funds, manufacture payment history, extract card rewards, or launder value — is prohibited. Transactions where payer and payee are the same person or under common control are treated as high-risk and may be declined, reversed, and investigated.
4.3 Structuring
Splitting, disguising, or misdescribing charges to evade fees, limits, monitoring, or reporting thresholds (“structuring”) is prohibited by Section 15.1 of the Payments & Rent Collection Terms and may be a criminal offense under AML law. This includes breaking one rent obligation into artificial pieces or mislabeling non-rent transfers as rent.
4.4 Card Testing and Stolen Instruments
Using the platform to test stolen card numbers, process payments on instruments the payer is not authorized to use, or probe payment endpoints via the API is prohibited and actively monitored. Detected card testing results in immediate blocking, and we may report it to Stripe, card networks, and law enforcement.
4.5 Consequences
Suspected prohibited activity may lead to suspended Payment Services, held funds, reserves, Connected Account closure, and reporting to Stripe, card networks, regulators, or law enforcement, as set out in Sections 15.2 and 16 of the Payments & Rent Collection Terms and the enforcement ladder in the Business Terms of Service (warning → content removal → temporary suspension → permanent termination).
5. Account Freeze Rules
A freeze is our most disruptive tool, so we use it deliberately. This section explains when freezes happen, what keeps working, and how to get unfrozen.
5.1 When Freezes Occur
We may freeze an account or its Payment Services when we reasonably suspect fraud, money laundering, sanctions exposure, account takeover, or other prohibited activity; when required by law, court order, a regulator, a card network, or Stripe; or when your Connected Account is suspended or closed by Stripe as described in Section 3.5 of the Payments & Rent Collection Terms. Freezes are scoped to the risk: where possible we restrict the affected feature rather than the whole account.
5.2 What Stays Accessible
During a payments freeze, you can generally still sign in, view your dashboard and transaction history, export your records, and communicate with support. New tenant payments may be declined or paused, and payouts may be held. Security deposit funds remain in the segregated custodial account described in Section 12 of the Payments & Rent Collection Terms and are handled under that section, not swept into a freeze.
5.3 How to Resolve
The fastest path out of a freeze is responsiveness: provide the documents and explanations requested, correct any verification gaps, and answer source-of-funds questions completely. Where we are permitted to tell you the reason, your dashboard and our notices will describe the remediation path. Once the underlying issue is resolved, we restore services and release held funds promptly, subject to any reserve or continued hold under Sections 8 and 16.3 of the Payments & Rent Collection Terms.
5.4 Escalation and Appeals
If you believe a freeze is mistaken, contact [email protected] first. If the issue is not resolved, you may appeal within 14 calendar days to [email protected]. EU and UK payment-related complaints may be sent to [email protected] and will be acknowledged within 72 hours, with a target resolution of 15 business days. Some freezes are legally compelled, and in those cases our discretion — and what we can disclose — is limited.
6. Cooperation with Processors & Authorities
Fighting financial crime is a team effort between Tentunit, Stripe, the card networks, and public authorities. This section describes how that cooperation works.
6.1 Stripe Compliance Programs
Payments on Tentunit Business run through Stripe, Inc. (US), Stripe Payments Europe, Ltd. (authorized by the Central Bank of Ireland), and Stripe Payments UK, Ltd. (regulated by the FCA). Stripe’s regulated AML, sanctions, and fraud programs apply to every transaction, and the Stripe Terms flow down to you through your Connected Account. We share identity, transaction, and risk data with Stripe as described in Section 18 of the Payments & Rent Collection Terms, and we participate in network- and Stripe-mandated risk and remediation programs.
6.2 Law Enforcement Requests
We respond to facially valid legal process — subpoenas, court orders, warrants, and equivalent instruments in the EU and UK — and may disclose account and transaction information in response. Where the law permits and it would not compromise an investigation, we notify affected customers of legal demands for their data, as described in the Tentunit Privacy Policy. We may also proactively report suspected unlawful activity where the law requires or permits.
6.3 Sanctions Lists
We and Stripe screen against applicable sanctions lists, including U.S. OFAC lists and EU and UN sanctions regimes (and their UK equivalents). We may decline, suspend, or terminate service to any person or entity on an applicable list or in a comprehensively sanctioned jurisdiction, and we may block or reject transactions where required by law, without prior notice and without liability.
6.4 Your Duty to Report
If you suspect the Payment Services are being used for fraud, money laundering, or sanctions evasion — for example, a tenant offering to route unrelated funds through rent payments — you are required under Section 4.3 of the Payments & Rent Collection Terms to notify us. Reports can be sent to [email protected]; security vulnerabilities should go to [email protected].
Tentunit, Inc. · Delaware, USA