Understand compliance requirements for agent payments: KYC ownership, cardholder identity, and ToS pitfalls

Steps

1. Establish the legal principal: in every agent payment flow, a human or legal entity must be the named accountholder on the card and the responsible party for all transactions — the agent is a tool acting on their behalf, not an independent financial actor; document this relationship explicitly.
2. Complete KYC for the human or business principal through your PSP or card issuer's onboarding flow before enabling any agent spending; the KYC is on the human, not the agent, but the agent's spending activity will be attributed to that identity.
3. Review the ToS of every PSP, card network, and merchant you plan to use with an agent: Visa and Mastercard rules, many PSP agreements, and most merchant agreements explicitly prohibit automated entry of payment credentials or bot-driven purchases; confirm your use case is permitted in writing where possible.
4. For platforms that issue cards to businesses (Stripe Issuing, Marqeta, etc.): the issued card must be in the name of the business or an authorized employee, not an AI agent; the business bears full liability for agent-initiated charges.
5. For agent-to-agent payment flows: consult a payments lawyer on money transmission licensing requirements in your jurisdiction; in many US states and internationally, facilitating payments between third parties requires a money transmitter license even if amounts are small.
6. Maintain a compliance record: documentation of the human principal's consent to agent spending, the scope of delegated authority, and the KYC record; retain for the duration required by your PSP agreement and applicable law.