Halyard Pay · Policy Updates Powered by Carver Agents

Mastercard SPME §11.2.6 · Jun 2022 → May 2023

MATCH Record Retention

substantive

The update changes record retention rules by requiring Acquirers to keep all MATCH records related to Merchants, Sponsored Merchants, or ATM owners for at least two years after their respective agreements end, whereas previously only retention and easy retrieval were recommended. The automatic five-year purge by Mastercard remains unchanged.

Sources Mastercard SPME · Jun 2022 · page 136 PDF Mastercard SPME · May 2023 · page 146 PDF KYB Acquirer current
Also in §11.x this release substantive §11.1.1 System Features substantive §11.2 MATCH Standards substantive §11.2.1 Certification substantive §11.4 Merchant Removal from MATCH substantive §11.5 MATCH Reason Codes
Why these edits? The requirement for Acquirers to retain MATCH records related to Merchants, Sponsored Merchants, or ATM owners for at least two years after agreement termination represents a new explicit obligation on data retention extending beyond previous recommended practices.
Mastercard SPME §11.2.6
This section was substantively restructured between versions (23% text overlap). Compare the texts directly below.
Before · Jun 2022 · page 136

An Acquirer should retain all MATCH records returned by Mastercard to substantiate that the Acquirer complied with the required procedures. Mastercard recommends that the Acquirer retain these records in a manner that allows for easy retrieval. Merchant records remain on the MATCH system for five years. Each month, MATCH automatically purges any Merchant information that has been in the database for five years. NOTE: The MATCH system database stores inquiry records for 360 days.

After · May 2023 · page 146

Merchant records remain on the MATCH system for five years, at which point they are automatically purged from the MATCH system. The Acquirer must retain all MATCH records concerning a Merchant, Sponsored Merchant, or ATM owner for a minimum of two years after the data that the Merchant Agreement, Sponsored Merchant Agreement, or ATM Owner Agreement, as applicable, is terminated or expires. NOTE: The MATCH system database stores inquiry records for 360 days.

Halyard Pay · 2 files
program: Acquirer KYB


- authority: Mastercard SPME §2.1


+ authority: Mastercard SPME 2.1, 11.2.6


required_documents:


  - incorporation


  - beneficial_ownership


  - aml_screen


  - license_verification


min_review_cycle_days: 365


suspension_trigger: document_collection_failure


record_retention_years: 7


aml_watchlist_sources:


  - ofac_sdn


  - eu_consolidated


agent_owner: kyb_agent


+ # The Acquirer must specifically retain all MATCH records concerning any Merchant, Sponsored Merchant, or ATM owner for at least two years following the termination or expiration of the related agreement, per Mastercard SPME 11.2.6.


+ # This retention requirement updates prior guidance by imposing a defined minimum retention period beyond the MATCH system's internal data purging schedule.

Acquirer KYB (Know Your Business) Obligations

Acquirers processing transactions on the Mastercard network are required to perform

Know Your Business (KYB) due diligence on merchants before onboarding and on a

recurring basis thereafter. Halyard Pay, as an acquirer, must collect and verify a

minimum set of documents for each merchant to establish business legitimacy, confirm

beneficial ownership, and satisfy anti-money laundering screening requirements.

When this policy applies

This policy applies to all new merchant onboarding and to all periodic re-verification

reviews. Merchants that fail to supply required documentation within the stipulated

period must be suspended from processing until compliance is restored.

Required actions

  1. Collect all required KYB documents at onboarding prior to approval.

  2. Conduct AML screening against applicable watchlists before approval.

  3. Verify business licenses for regulated merchant categories.

  4. Schedule a full re-verification review at least once every 365 days.

  5. Document all verification outcomes and retain records for audit purposes.

6. Retain all MATCH system records related to Merchants, Sponsored Merchants, or ATM owners for a minimum of two years after termination or expiration of the applicable agreement, to comply with Mastercard's explicit record retention requirements.

Source authority: Mastercard SPME §2.1.��������2.1, 11.2.6.

policies/kyb_acquirer/policy.md — after applying change

Acquirer KYB (Know Your Business) Obligations

Acquirers processing transactions on the Mastercard network are required to perform

Know Your Business (KYB) due diligence on merchants before onboarding and on a

recurring basis thereafter. Halyard Pay, as an acquirer, must collect and verify a

minimum set of documents for each merchant to establish business legitimacy, confirm

beneficial ownership, and satisfy anti-money laundering screening requirements.

When this policy applies

This policy applies to all new merchant onboarding and to all periodic re-verification

reviews. Merchants that fail to supply required documentation within the stipulated

period must be suspended from processing until compliance is restored.

Required actions

  1. Collect all required KYB documents at onboarding prior to approval.

  2. Conduct AML screening against applicable watchlists before approval.

  3. Verify business licenses for regulated merchant categories.

  4. Schedule a full re-verification review at least once every 365 days.

  5. Document all verification outcomes and retain records for audit purposes.

6. Retain all MATCH system records related to Merchants, Sponsored Merchants, or ATM owners for a minimum of two years after termination or expiration of the applicable agreement, to comply with Mastercard's explicit record retention requirements.

Source authority: Mastercard SPME §2.1.��������2.1, 11.2.6.

Source authority: Mastercard SPME §11.2.6.

--- a/policies/kyb_acquirer/rules.yaml
+++ b/policies/kyb_acquirer/rules.yaml
@@ -1,5 +1,5 @@
 program: Acquirer KYB
-authority: Mastercard SPME §2.1
+authority: Mastercard SPME 2.1, 11.2.6
 required_documents:
   - incorporation
   - beneficial_ownership
@@ -12,3 +12,5 @@
   - ofac_sdn
   - eu_consolidated
 agent_owner: kyb_agent
+# The Acquirer must specifically retain all MATCH records concerning any Merchant, Sponsored Merchant, or ATM owner for at least two years following the termination or expiration of the related agreement, per Mastercard SPME 11.2.6.
+# This retention requirement updates prior guidance by imposing a defined minimum retention period beyond the MATCH system's internal data purging schedule.
--- a/policies/kyb_acquirer/policy.md
+++ b/policies/kyb_acquirer/policy.md
@@ -19,5 +19,6 @@
 3. Verify business licenses for regulated merchant categories.
 4. Schedule a full re-verification review at least once every 365 days.
 5. Document all verification outcomes and retain records for audit purposes.
+6. Retain all MATCH system records related to Merchants, Sponsored Merchants, or ATM owners for a minimum of two years after termination or expiration of the applicable agreement, to comply with Mastercard's explicit record retention requirements.
 
-Source authority: Mastercard SPME §2.1.
+Source authority: Mastercard SPME 2.1, 11.2.6.