Transparency. Integrity. Accountability.

 This page outlines the legal framework and compliance practices that govern Penitron’s operations. It is intended for existing and prospective investors, counterparties, and regulators.

Penitron Holdings LLC ("Penitron") is a U.S.‑domiciled investment adviser that offers private placements under Regulation D, Rule 506(c) of the Securities Act of 1933. We currently accept only accredited investors as defined by Rule 501 of Regulation D.

All securities offerings are conducted pursuant to available exemptions from registration, and no public solicitation is made. Marketing materials are provided solely for informational purposes and do not constitute an offer to sell or a solicitation of an offer to buy any security in any jurisdiction where such an offer or solicitation would be unlawful.

Trading in digital assets, derivatives, and other complex instruments involves substantial risk and may result in the loss of your entire investment. Past performance is not indicative of future results. Investors should be prepared to bear the risks inherent in these markets and, if necessary, seek independent professional advice.

Penitron maintains a comprehensive AML/CTF program that includes:

• Customer identification and verification (KYC/KYB)
• Sanctions and politically exposed person (PEP) screening
• Ongoing transaction monitoring and suspicious activity reporting
  Our procedures adhere to the USA PATRIOT Act, FinCEN guidelines, and FATF recommendations.

We collect only the information necessary to provide our services and comply with regulations. Data are encrypted in transit and at rest. We do not sell personal information to third parties. For additional details, see our Privacy Policy (link).

Penitron and its employees may invest personal capital alongside client accounts. All personal trading is subject to pre‑clearance and quarterly disclosure. An independent compliance consultant conducts annual conflict‑of‑interest reviews.

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Certain statements herein may constitute forward‑looking statements. These are subject to risks and uncertainties that could cause actual results to differ materially. Penitron undertakes no obligation to update or revise such statements.