Provision record
Gusto · Gusto Terms of Service · View original document ↗

Gusto OFAC Hold or Termination Without Notice

High severity High confidence Explicit document language Common · 181 of 352 platforms

Key Facts · in the document’s own words

What may Gusto do if it determines that the Employer or any of the Employer's Administrators are a Specially Designated National?
“Gusto may institute a hold on Employer's Bank Account or funds, or terminate this Agreement immediately without notice, if Gusto determines...that Employer or any of Employer's Administrators are a Specially Designated National...”
Version CA-V-007001, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
Gusto may institute a hold on the Employer's Bank Account or funds, or terminate the Agreement immediately without notice, if Gusto determines that the Employer or any of the Employer's Administrators are a Specially Designated National.
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This analysis describes what Gusto'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Gusto can take severe financial and contractual actions—including freezing funds and ending the Agreement without notice—based on its own determination regarding OFAC status.

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Interpretive note: The canonical claim captures both enumerated Gusto actions (hold and termination) because they arise from a single trigger condition and are closely related. The excerpt uses ellipses around 'determines' which may indicate additional conditions not quoted; confidence remains high for what is explicitly stated.

Consumer impact (what this means for users)

If Gusto determines you or any of your Administrators are a Specially Designated National, Gusto may freeze your bank account or funds or terminate the Agreement immediately and without notice.

How other platforms handle this

Amplitude High

for the benefit or on behalf of any person listed in any Sanctions-related list of designated persons maintained by the Office of Foreign Assets Control...or any person owned 50 percent or more by such person

Stripe High

We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism activities...export control, and prohibition of doing business with restricted persons...

Snapchat High

you are not a person who is barred from using the Services under the laws of the United States, the United Kingdom, or any other applicable jurisdiction — including, for example, that you do not appear on the U.S. Treasury Department's list...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Gusto may institute a hold on Employer's Bank Account or funds, or terminate this Agreement immediately without notice, if Gusto determines...that Employer or any of Employer's Administrators are a Specially Designated National...

Excerpt from Gusto's Terms of Service

Provision details

Document information
Document
Gusto Terms of Service
Entity
Gusto
Date stated by the document
Aug. 1, 2025
As printed in Gusto’s text (version CA-V-007001), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
April 19, 2026
Text quoted from version
CA-V-007001, captured Sept. 17, 2026
Record ID
CA-P-036146
Document ID
CA-D-000293
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-007001)
c2864616bf8a2de4ba7a45e8b53965a96865b11384784b449c235d607c1b78f8
Analysis generated
May 21, 2026 03:08 UTC
Methodology
Evidence
✓ Excerpt found verbatim in version CA-V-007001 (checked Oct. 5, 2026)
Citation Record
Entity: Gusto
Document: Gusto Terms of Service
Record ID: CA-P-036146
Version: CA-V-007001
Captured: 2026-09-17 00:44:55 UTC
SHA-256: c2864616bf8a2de4…
URL: https://conductatlas.com/platform/gusto/gusto-terms-of-service/provision/CA-P-036146/gusto-ofac-hold-or-termination-without-notice/
Accessed: Oct. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Gusto's Gusto OFAC Hold or Termination Without Notice clause do?

Gusto can take severe financial and contractual actions—including freezing funds and ending the Agreement without notice—based on its own determination regarding OFAC status.

How does this clause affect you?

If Gusto determines you or any of your Administrators are a Specially Designated National, Gusto may freeze your bank account or funds or terminate the Agreement immediately and without notice.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 181 platforms. See the full comparison.

Is ConductAtlas affiliated with Gusto?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Gusto.