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