Review of Spark's trust model

Privacy, control, and safety

Grid's contract assigns the compliance and execution decision to Lightspark

Lightspark's published Grid agreement template assigns Lightspark responsibility for end-user KYC, KYB, AML, and sanctions screening. It also assigns Lightspark control over its onboarding, verification, transaction-execution, suspension, and termination decisions. 1

1 sourceEvidence reviewed through July 14, 2026

What the evidence shows

Technical and product details

  1. Documented behavior

    Lightspark's published Grid MSA template makes Lightspark solely responsible for End-User KYC, KYB, AML, and sanctions-screening obligations. 1

    Supporting material shown on this page

    Grid MSA section 2.5Pinned source code · github.com · checked 2026-07-14
    Relevant lines from the pinned source · open raw file
    55- **(a) Onboarding and End User Terms Acceptance.** Each End User must accept the End User Terms and complete Lightspark's know-your-customer and know-your-business verification process as preconditions to accessing or using the Grid Transaction Services. Lightspark's onboarding flow will require ea
56- **(b) Platform Presentation of End User Terms.** Platform shall, prior to permitting any End User to access the Grid Transaction Services, present each such End-User with (i) a clear and conspicuous disclosure identifying Lightspark as the provider of payment services and stating that the Lightspa
57- **(c) Platform Records of End Users' Consent to Terms.** Platform shall create and maintain, for each End-User acceptance event, a record containing at minimum: (i) a unique identifier for the End-User; (ii) the date and time of acceptance in Coordinated Universal Time; (iii) the IP address of the
58- **(d) Platform Bound by End User Terms.** By executing this Agreement, Platform also agrees to the terms and conditions of the End User Terms, which apply when Platform itself receives the Grid Transaction Services as a user (including when Platform initiates Grid Transactions on behalf of its mer
59- **(e) Lightspark Compliance Responsibilities.** Lightspark shall be solely responsible for performing all know-your-customer, know-your-business, anti-money laundering, and sanctions screening obligations with respect to End Users in connection with the Grid Transaction Services, in accordance wit
60- **(f) Platform Liability for Onboarding Failures.** Platform shall be liable for any losses, damages, or claims arising from Platform's failure to properly present the End User Terms to End Users in accordance with this Section 2.5, or from Platform permitting End Users to access or use the Grid T
  2. Documented behavior

    It gives Lightspark exclusive control over its decisions on onboarding, verification, transaction execution, suspension, and termination. A platform may instruct suspension or termination by API or written notice, including for “any other reason.” 1

    Supporting material shown on this page

    Grid MSA section 2.5Pinned source code · github.com · checked 2026-07-14
    Relevant lines from the pinned source · open raw file
    55- **(a) Onboarding and End User Terms Acceptance.** Each End User must accept the End User Terms and complete Lightspark's know-your-customer and know-your-business verification process as preconditions to accessing or using the Grid Transaction Services. Lightspark's onboarding flow will require ea
56- **(b) Platform Presentation of End User Terms.** Platform shall, prior to permitting any End User to access the Grid Transaction Services, present each such End-User with (i) a clear and conspicuous disclosure identifying Lightspark as the provider of payment services and stating that the Lightspa
57- **(c) Platform Records of End Users' Consent to Terms.** Platform shall create and maintain, for each End-User acceptance event, a record containing at minimum: (i) a unique identifier for the End-User; (ii) the date and time of acceptance in Coordinated Universal Time; (iii) the IP address of the
58- **(d) Platform Bound by End User Terms.** By executing this Agreement, Platform also agrees to the terms and conditions of the End User Terms, which apply when Platform itself receives the Grid Transaction Services as a user (including when Platform initiates Grid Transactions on behalf of its mer
59- **(e) Lightspark Compliance Responsibilities.** Lightspark shall be solely responsible for performing all know-your-customer, know-your-business, anti-money laundering, and sanctions screening obligations with respect to End Users in connection with the Grid Transaction Services, in accordance wit
60- **(f) Platform Liability for Onboarding Failures.** Platform shall be liable for any losses, damages, or claims arising from Platform's failure to properly present the End User Terms to End Users in accordance with this Section 2.5, or from Platform permitting End Users to access or use the Grid T

Interpretation

Why this matters for Spark's trust model

For the Spark-backed Grid product, Lightspark is not merely passive infrastructure awaiting a platform decision. The contract puts the compliance judgment and the execution/suspension response in Lightspark's hands. 1

This section states the trust-model consequence of the cited evidence. Conditional or inferred claims remain bounded by the next section.

Scope control

What this does not establish

  • This is a Grid template and does not establish identical terms for every customer or ordinary non-Grid Spark users. 1

Sources and excerpts

Primary sources

The relevant details and available source-code excerpts appear alongside the claims above. This list preserves the complete original-source trail for independent verification.

1

Grid MSA section 2.5

Pinned source code · github.com · Pinned or archival · checked 2026-07-14

Open original source

How sources, absence findings, and limitations were evaluated