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The policy states that customers acknowledge and agree that Betterment will compare their identifying information against government-provided lists of suspected terrorists as part of its compliance procedures.
This analysis describes what Betterment's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision discloses that customer identity data is screened against government terrorism watchlists, a practice required under federal Bank Secrecy Act and USA PATRIOT Act obligations for financial institutions, and reflects a mandatory compliance obligation rather than a discretionary data use.
The updated policy discloses a new Fully Paid Securities Lending program through Apex Clearing, under which Betterment will share customer personal information and account details with Apex if customers choose to participate. The revised terms also establish that generative AI service providers have committed that personal information will not be used for model training. For customers participating in promotional offers requiring offline fulfillment, the policy now explicitly states that personal information including mailing address may be shared with third-party partners. You can review the FPSL Program supplemental disclosures for details about the securities lending arrangement, or choose not to participate in the program.
View change record →The agreement establishes that customer identifying information will be checked against government terrorism screening lists. This practice is a standard regulatory requirement for financial institutions under federal law and does not represent a discretionary data use by Betterment.
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"You understand and agree that Betterment will compare your identifying information with government-provided lists of suspected terrorists.Excerpt from Betterment's Privacy Policy
1) REGULATORY LANDSCAPE: This provision reflects obligations under the USA PATRIOT Act, Bank Secrecy Act Customer Identification Program (CIP) requirements, and OFAC sanctions screening obligations applicable to financial institutions. FinCEN and OFAC have enforcement authority. This practice is mandatory for registered investment advisors and broker-dealers under applicable federal regulations. 2) GOVERNANCE EXPOSURE: Low. This is a mandated compliance activity rather than a discretionary data use. The disclosure is consistent with standard financial institution privacy notice requirements under GLBA and applicable AML/KYC regulatory frameworks. 3) JURISDICTION FLAGS: This obligation applies federally and does not create differentiated state-level exposure. Non-U.S. customers using Betterment services, if any, may have questions about cross-border data sharing with U.S. government lists. 4) CONTRACT AND VENDOR IMPLICATIONS: No specific contract or vendor implications beyond confirming that list-screening vendors are subject to appropriate confidentiality and data security agreements. 5) COMPLIANCE CONSIDERATIONS: Standard compliance maintenance; confirm that screening procedures are current, that watchlist data is sourced from authorized government databases, and that screening results are handled with appropriate access controls and retention practices.
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This provision discloses that customer identity data is screened against government terrorism watchlists, a practice required under federal Bank Secrecy Act and USA PATRIOT Act obligations for financial institutions, and reflects a mandatory compliance obligation rather than a discretionary data use.
The agreement establishes that customer identifying information will be checked against government terrorism screening lists. This practice is a standard regulatory requirement for financial institutions under federal law and does not represent a discretionary data use by Betterment.
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