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Insights and Expertise

should still ask the tough questions of their AI suppliers
and consider whether the answers are reliable or not.

Payment platforms are already highly aware of risks as-
sociated with data breach, notably because they often as-
Legal ease: sume liability for payment network fines related to PCI-
non-compliance and data breaches. This gives payment
platforms a leg-up on holding AI providers to data secu-
rity standards that are the law of the land in payments.
2. Perplexity: The case
AI, payments All of AI is holding its breath over Amazon.com Services

LLC v. Perplexity AI, Inc., No. 26-1444 (9th Cir. 2026). Am-
and law: azon alleged that Perplexity's AI shopping agent caused
or facilitated access to Amazon's platform in violation of
A tri-state bonanza Amazon's Terms of Use when users used the Perplexity
bot to shop on Amazon.

By Adam Atlas On March 10, 2026, the U.S. District Court for the Northern
District of California granted Amazon an injunction al-
Attorney at Law lowing it to block Perplexity's agents. Perplexity is appeal-
ing. When you and I go to Amazon to order paper towels,
aster. Cheaper. Better. That's all you can hear milling around on the site often results in buying a bunch
over here in the tri-state area of AI, payments of other stuff. When you or I send a Perplexity agent to
and law. Like cars before seatbelts, there will be buy paper towels for us, the bot stays on task and doesn't
F crashes along the way as payment profession- get lured in by deals or advertising.
als rush head-long into harnessing the irresistible tools
powered by AI. Here are four legal issues that payment This presents a challenge to Amazon because it earns rev-
professionals should consider as they tumble into the con- enue from advertising that we humans fall for and from
temporary reality of pervasive AI situations. the additional sales made to us. Unflappable agents are
not big spenders. Residual-Based lending is here.
1. Where is the data? FCSB evaluates true

Most AI data processing happens in those vast data cen- If I had to bet on where this whole issue is going, like A smart first step starts with a scan. cash flow to offer
ters popping up all over the place and not on your own restaurants, taxis and hotels before it, Amazon will most business purpose
computer or server. This is not the end of the world; most likely cave to being a supplier to an army of shopping bots, lending solutions.
payment platforms do not run their own servers like they letting go of some of its connection to us humans. Even
did 20 years ago. Most payment platforms (directly or in- when we humans shop at Amazon, our orders go through
directly) procure hosting services or software-as-a-service several computing instances such as: (i) a local device; (ii) SCAN questionnaire
(SaaS) plus hosting services using backbone suppliers like a browser; (iii) a router; (iv) a modem; (v) an ISP switch; (vi) Interested in how RBL works at First Central Savings Bank (FCSB)? Share a
Azure or Amazon AWS. the ISP itself and countless other hops between machines few basics and we’ll take a preliminary look at your scenario.
and systems.
In plain English, when you log in to your business gmail • No credit app. *
account, all the data for that account is in a Google server The introduction of one more layer, a Perplexity bot, is • No hard pull. *
somewhere far from your phone or desktop. The idea that merely a subtle variation on the pre-existing reality where
data is no longer local is not new. What is new is that a a string of machines stand between buyer and seller. Giv- • No commitment.
lot of data put into AI models becomes part of vast pools en the billions of dollars earned from ad revenue, there are
of data that make AI better. For now, AI is "smart" only grounds to believe that there will be some paradigm shift, Scan the QR to submit your information for a preliminary
because it has seen everyone else's way of doing the thing but businesses will always advertise and consumers will
you are learning about. always fall for ads. review — it takes seconds. No credit application is required at this stage.

Back to the issue then. When a payment processor uses AI Ads are already popping up in various AI chats, and AI
to manage risk on a portfolio of merchants, the processor algorithms can easily steer consumers one way or another. FCSB is a residual based lender, offering ISOs and independent agents a flexible Chad Horal, FVP, Director of
should consider how much merchant data is going to the Unless Amazon wants to retreat to IRL/in-store only trans- loan program built around real cash flow after essential operating expenses. This Merchant Services 516-506-4571
AI platform servers and whether that data could become actions, fending off the bots is perhaps a fruitless task. structure may provide a clearer picture than credit only models and may create myfcsb.com/rbl
identifiable to anyone other than the processor itself. opportunities where traditional underwriting reaches its limits.
Assuming my guess is right, and the shopping bots are
In the fullness of time, I expect AI platforms to be scored here to stay, there are important takeaways for payment *No credit application or hard inquiry is required at the preliminary inquiry stage; additional information and
on how well they avoid or discard identifiable data. For professionals. Fraud is shooting up exponentially. Proces- a credit check may be required if you proceed. Submission does not constitute an application, approval, or
now, users are often in the dark, but payment platforms sors and their ISOs should consider exactly who carries commitment to lend. This is not an offer of credit. All extensions of credit are subject to underwriting and
approval; terms and eligibility vary. Financing is intended for business purposes. Information submitted will
28 be handled in accordance with the First Central Savings Bank's Privacy Notice available at myfcsb.com.