Draft, pre-launch. Baasto does not yet hold customer funds or issue cards. Commitments below describe how Baasto will operate once launched, and they are under review by counsel. This page does not create a contract; our Terms of Service govern the service. Legal citations are to help readers find the underlying rule, not legal advice. Which rules apply to Baasto, and how, is being confirmed with counsel.

Our commitments: what Baasto won't do, can't do, and must report.

Version 0.2 · Last updated November 1, 2026

Payments run on trust. This page is written for everyone who has to trust us: customers, merchants and vendors, banks and card partners, and governments and regulators. Each commitment links to the law or standard behind it.

CustomersVendorsPartnersRegulators

1. What we will not do

These are limits set by law, by our licensing, or by our partners. We won't make exceptions to them.

2. What we cannot do

Baasto isn't built for any of the following. They aren't features we offer, and some of these limits go further than the law requires.

3. What we are legally obligated to report

As a payments business working with US-regulated partners, Baasto expects to have the following duties. Where they apply, we will:

Because of these duties, we may freeze, limit or close an account without notice, and we may not always be able to explain why.

4. What we are legally obligated to keep

5. Sanctions

6. How we verify people

7. How we protect your money

8. How we protect your data

See our full Privacy Notice.

9. Your rights and how to complain

10. Our commitments to vendors and partners

11. Our commitments to governments and regulators

12. What's live today, and what's planned

We'd rather be honest than impressive. As of this page's date:

ItemStatus
Website, Terms, Privacy Notice, this pageLive (draft)
Watchdog reporting channelLive
Double-entry ledger and reconciliationBuilt, in test
Merchant-locked cards with spending capsBuilt, in test
Customer funds held, cards issued to the publicNot yet
Card issuer and banking partner approvalPlanned
FinCEN registration and legal opinionPlanned
Identity and sanctions screening vendorsPlanned
Independent AML reviewPlanned before launch

13. General disclaimers

Questions? Email hello@baasto.com.

Sources

  1. Bank Secrecy Act, 31 U.S.C. § 5311 and following. law.cornell.edu
  2. 31 U.S.C. § 5318(g) (suspicious activity reporting and confidentiality); 31 U.S.C. § 5324 (structuring). § 5318 · § 5324
  3. Money services business definitions, 31 CFR 1010.100(ff), and registration, 31 CFR 1022.380 (FinCEN Form 107, renewed every 2 years). § 1010.100 · § 1022.380
  4. Prepaid access, 31 CFR 1010.100(ww), and prepaid access recordkeeping, 31 CFR 1022.420. § 1022.420
  5. Anti-money-laundering programs for money services businesses, 31 CFR 1022.210 (compliance officer, controls, training, independent review). § 1022.210
  6. Suspicious activity reports by money services businesses, 31 CFR 1022.320 ($2,000 threshold, 30-day filing, 5-year retention, confidentiality). § 1022.320
  7. Currency transaction reports, 31 CFR 1022.310 and 1010.311. § 1022.310
  8. Record retention, 31 CFR 1010.430 (5 years). § 1010.430
  9. FinCEN information requests ("314(a)"), 31 CFR 1010.520. § 1010.520
  10. Voluntary information sharing between financial institutions ("314(b)"), 31 CFR 1010.540. § 1010.540
  11. Anti-money-laundering whistleblower protections, 31 U.S.C. § 5323. § 5323
  12. US Treasury, Office of Foreign Assets Control: sanctions programs and the Specially Designated Nationals list. ofac.treasury.gov
  13. Somalia Sanctions Regulations, 31 CFR Part 551; Global Terrorism Sanctions Regulations, 31 CFR Part 594. Part 551 · Part 594
  14. OFAC Reporting, Procedures and Penalties Regulations, 31 CFR Part 501, including 501.603 (blocked property reports), 501.604 (rejected transactions) and 501.601 (recordkeeping, extended to 10 years in 2025). Part 501
  15. UN Security Council Resolution 2713 (2023), Al-Shabaab sanctions regime, and the UN consolidated sanctions list. un.org
  16. Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 and following, and its privacy rule (Regulation P), 12 CFR Part 1016. § 6801 · Part 1016
  17. FTC Standards for Safeguarding Customer Information (Safeguards Rule), 16 CFR Part 314, including breach notice to the FTC. Part 314
  18. PCI Security Standards Council, PCI Data Security Standard (PCI DSS). pcisecuritystandards.org
  19. Financial Action Task Force, International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation (the FATF Recommendations), including Recommendations 6 (targeted sanctions), 10 (customer due diligence), 12 (politically exposed persons), 14 (money or value transfer services), 16 (wire transfers) and 20 (suspicious transaction reporting). fatf-gafi.org
  20. Federal Republic of Somalia: Anti-Money Laundering and Countering the Financing of Terrorism Act (2016), which established the Financial Reporting Center; and the Data Protection Act (2023). Djibouti: the anti-money-laundering law and Central Bank of Djibouti requirements, to be confirmed with local counsel.
  21. FDIC: what deposit insurance covers, and what it doesn't. fdic.gov
  22. Uniform Law Commission, Revised Uniform Unclaimed Property Act (2016), adopted in various forms by US states. uniformlaws.org