The same contract expressly authorizes sanctions-based refusal and freezing

What the evidence shows

Technical and product details

1. Documented behavior

   The MSA says Lightspark may refuse, delay, reverse, or freeze a Grid transaction because of law, suspected fraud or illegal activity, sanctions-screening results, or another identified risk. 2

   Supporting material shown on this page

   section 2.8(h)Pinned source code · github.com · checked 2026-07-14

   75- **(c)** Platform Internal Accounts hold funds for the benefit of Platform, and End User Internal Accounts hold funds for the benefit of the applicable End User in accordance with the End User Terms;
   76- **(d)** Grid Transactions are available only in Supported Locations and with respect to supported currencies and digital assets as set forth in the Documentation;
   77- **(e)** Lightspark will provide End Users with transaction quotes that include applicable exchange rates and fees, and upon an End User's acceptance of a quote, Lightspark will execute the Grid Transaction in accordance with the terms of the quote and the End User Terms;
   78- **(f)** Platform and each End User is responsible for ensuring the accuracy and completeness of all instructions provided in connection with any Grid Transaction, including any recipient information, wallet addresses, transaction amounts, or other required information;
   79- **(g)** certain Grid Transactions, including those involving digital assets, may be irreversible, and losses due to erroneous, fraudulent, or accidental transactions may not be recoverable;
   80- **(h)** Lightspark may, in its sole discretion, refuse to execute any Grid Transaction, delay the execution of any Grid Transaction, or reverse or freeze any Grid Transaction if Lightspark determines, in its sole discretion, that such action is required or reasonably advisable due to compliance wi
   81- **(i)** Platform acknowledges that Lightspark maintains a direct account relationship with each End User through End User Internal Accounts, as governed by the End User Terms. Platform has no ownership interest in, control over, or right to direct the disposition of funds held in any End User Inte

2. Documented behavior

   It separately permits Lightspark to modify, suspend, or discontinue a service component, supported network, or digital asset because of sanctions results and other risks. 1

   Supporting material shown on this page

   Grid MSA section 2.1Pinned source code · github.com · checked 2026-07-14

   43## 2. Service and API Usage
   44
   45**2.1 Lightspark Services; License.** During the applicable Term, Lightspark will provide the Service as detailed in the relevant Order. Subject to Platform's ongoing compliance with the terms of the Agreement, Lightspark hereby grants Platform a non-exclusive, non-transferable, non-sublicensable, i

Scope control

What this does not establish

• The contract does not identify whether Grid, private Sparkcore, an SSP, an SO, or several components enforce a particular decision. 12

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.