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Urgent Compliance Updates

Bernardo Simonassi
Bernardo Simonassi
•

These compliance updates take effect on October 15, 2025 and require action across your customer onboarding and terms of service flows.

TL;DR

  • New terms of service available (breaking changes)
  • Customer creation updates (breaking changes)

New terms of service version available

All your customers will be required to accept the new version of our terms of service. This is necessary to allow BlindPay to issue virtual accounts, create wallets and process payments on behalf of them.

Every time you try to create a quote, an error message please_accept_terms_of_service will show up. When you see that, you should pop up the terms of service link and make your customer accept. Consult the terms of service guide for integration details.

You will also receive updated tos.accept webhook events—review the webhook documentation to handle them correctly.

Customer creation updates

The following fields are now updated:

  • The fields phone_number and selfie_file are now mandatory for individuals. This is necessary because our US banking partner will require them in the future, so we're already anticipating this.
  • The field individual_holding_doc_front_file is deprecated for enhanced KYC because of the addition of selfie_file.
  • The field website is now mandatory for businesses.
  • The prohibited and high-risk countries list was updated. All customers from high-risk countries must go through enhanced KYC verification.
  • We're adding new fraud checks when analyzing customer data. If the KYC is rejected, you'll see details in fraud_warnings.

Update your onboarding forms and validation logic ahead of the deadline to avoid interruptions.

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Blind Pay, Inc. (“BlindPay”) is a United States-based financial technology and payments infrastructure company, incorporated in the State of Delaware on May 2, 2024. BlindPay is duly registered as a Money Services Business (“MSB”) with the Financial Crimes Enforcement Network (“FinCEN”) under registration number 31000277566153. BlindPay is not a state-licensed money transmitter and does not, in its own capacity, engage in regulated money transmission services. All such regulated activities are conducted exclusively through, and under the licenses of, duly authorized financial institution partners. BlindPay's role is limited to providing financial technology, virtual account management, payment processing, and related payments infrastructure services that facilitate payment flows and account functionalities. These services are provided in coordination with its licensed partners and in compliance with applicable federal MSB requirements and relevant state regulatory frameworks.

Blind Pay, LLC (“BlindPay”) is a Delaware limited liability company formed on June 24, 2025. BlindPay is duly registered as a Money Services Business (“MSB”) with the Financial Crimes Enforcement Network (“FinCEN”) under registration number 31000318334247 and is listed in the Nationwide Multistate Licensing System (“NMLS”) under NMLS ID #2745309.

BLIND PAY SOCIEDADE PRESTADORA DE SERVIÇOS DE ATIVOS VIRTUAIS LTDA. (“BlindPay”) is a Virtual Asset Service Provider (“VASP”) operating in Brazil. The company is presently completing the regulatory adaptation process required of Virtual Asset Service Provider Companies (SPSAV) under Central Bank of Brazil Resolution No. 520/2025, and remains subject to the transitional regime set forth in Article 88 of that Resolution. Registered address: Avenida Princesa Isabel, nº 15, Sala 1405, Edifício Martinho de Freitas, Centro, Vitória/ES, 29010-361.

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