payments · FTC Act §5 · EEOC Title VII · NAIC Model Bulletin
Payout Rail / Clear-Before-Wire
Per-withdraw bind at $0.05–$0.25/hop scales to operator millions
—Agent payout + affiliate withdraw fraud
Regulatory exposure — commonly overlooked:
Operator skips gate to reduce friction — owns chargeback and runner fraud. · Federal agencies disagree on AI approach — but examiners agree internal logs are insufficient.
TAM / Exposure
Platform rake on every hop — sleep-money shape
Insurance lines
Fidelity · Cyber
Exhibit authority
US Federal Exhibit — Operator Payout Authorization Pack