Privacy at Scale

How the privacy-focused model scales from banking and regulatory perspective.

Pre-TGE, we've received a version of the following question a few times:

Maintaining privacy while remaining fully compliant is a challenge. How do you structure regulatory/vendor risk as volume scales?

It's a great question, and is absolutely a significant risk.

The intuition is that we’re operating under the same regulatory structure that allows someone to walk into Target and buy a prepaid Visa gift card with cash.

There’s no ID upload required there either.

Both Target (in that example) and Laso Finance operate under FinCEN’s Prepaid Access Final Rule, which was published in 2011.

It provides many guard rails, such as, but not limited to:

1. Maximum card load of $1,000.

2. Maximum spend of $1,000 in a day.

3. [the seller] has policies and procedures in place that are reasonably adapted to prevent the sale of more than $10,000 of any type of prepaid access to any one person on any one day.

For more detail on our AML processes, read our compliance page.

By following this structure, we get access to sell in a very large market with a long-established regulatory framework.

Now, of course, regulations can change, and that’s absolutely a business risk.

We also rely on relationships with issuing banks, and those banks always have discretion over which prepaid programs they support. They may determine that a program is now too high of a risk and they cannot support it. Those are both real risks. But, today we’re operating within a very well-understood regulatory framework that has existed for many years.