“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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You agree that you are not prohibited from receiving the Services under the laws of the United States, England, Wales, Canada or other applicable jurisdiction. For example, you are not on the U.S. Treasury Department's list of Specially Designated Nationals...
Customer will comply with all applicable federal laws, regulations and rules that prohibit or restrict the export or re-export of the Platform Services or software outside the United States, and will complete all undertakings required by those laws...
"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 178 platforms. See the full comparison.
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