Halyard Pay · Policy Updates Powered by Carver Agents

Mastercard SPME §11.2 · Jun 2022 → May 2023

MATCH Standards

substantive

The updated rules now mandate all Acquirers globally to use MATCH, encompassing both adding terminated Merchants under certain conditions and querying the MATCH database. Additionally, Acquirers are charged an annual usage fee and per inquiry fees. This replaces the prior guidance cautioning against using MATCH for minor discretionary issues and clarifies obligations for compliance.

Sources Mastercard SPME · Jun 2022 · page 135 PDF Mastercard SPME · May 2023 · page 144 PDF KYB Acquirer current
Also in §11.x this release substantive §11.1.1 System Features substantive §11.2.1 Certification substantive §11.2.6 MATCH Record Retention substantive §11.4 Merchant Removal from MATCH substantive §11.5 MATCH Reason Codes
Why these edits? The updated Mastercard SPME section 11.2 now mandates all Acquirers globally to actively use MATCH by both adding terminated Merchants under certain conditions and querying the MATCH database, replacing prior guidance limiting MATCH use. This substantially impacts Acquirer KYB obligations, requiring adherence to mandatory MATCH usage and payment of associated fees.
Mastercard SPME §11.2
This section was substantively restructured between versions (11% text overlap). Compare the texts directly below.
Before · Jun 2022 · page 135

Security Rules and Procedures—Merchant Edition • 22 February 2022

Acquirers may not use or threaten to use MATCH as a collection tool for minor Merchant discretionary activity. One of the defined reason codes in Table 11.4 must be met or suspected (at decision to terminate) to justify a Merchant addition. Acquirers that use or threaten to use MATCH as a collection tool for minor Merchant discretionary activity are subject to noncompliance assessments as described in Table 11.3. An Acquirer that fails to enter a Merchant into MATCH is subject to a noncompliance assessment, and may be subject to an unfavorable ruling in a compliance case filed by a subsequent Acquirer of that Merchant.

After · May 2023 · page 144

Mastercard mandates that all Acquirers with Merchant activity use MATCH.5 To use means both to: 3 If country is USA. 4 If country is not USA. 5 Acquirers globally are assessed an annual MATCH usage fee of USD 5,000. In addition, Acquirers are assessed a MATCH inquiry fee (per Member ID/ICA number) for each MATCH inquiry. MATCH System 11.1.2.3 Phonetic Possible Matches Security Rules and Procedures—Merchant Edition • 7 February 2023

  • Add information about a Merchant that is terminated while or because a circumstance exists (See section 11.2.2), and
  • Inquire against the MATCH database Customers must act diligently, reasonably, and in good faith to comply with MATCH Standards.
Halyard Pay · 2 files
program: Acquirer KYB


- authority: Mastercard SPME §2.1


+ authority: Mastercard SPME §11.2


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


+ match_usage_required: true


+ match_usage_fee_usd: 5000


+ match_inquiry_fee_applies: true


+ match_mandates:


+   - add_terminated_merchants_when_circumstance_exists


+   - inquire_against_match_database


+ match_compliance_expectation: "Diligent, reasonable, and good faith use per Mastercard standards"  


+ # Updated to reflect Mastercard SPME §11.2 requirement for all Acquirers globally to actively use MATCH, including adding terminated Merchants and inquiry obligations, replacing prior optional use guidance.

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. Utilize the MATCH system as mandated by Mastercard by:

- Adding information about terminated merchants under defined circumstances.

- Inquiring against the MATCH database before onboarding and during monitoring.

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

Halyard Pay must be aware of Mastercard’s annual MATCH usage fee and inquiry fees, and

ensure compliance with all MATCH standards through diligent, reasonable, and good

faith actions.

Source authority: Mastercard SPME §2.1.§2.1, §11.2.

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. Utilize the MATCH system as mandated by Mastercard by:

- Adding information about terminated merchants under defined circumstances.

- Inquiring against the MATCH database before onboarding and during monitoring.

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

Halyard Pay must be aware of Mastercard’s annual MATCH usage fee and inquiry fees, and

ensure compliance with all MATCH standards through diligent, reasonable, and good

faith actions.

Source authority: Mastercard SPME §2.1.§2.1, §11.2.

Source authority: Mastercard SPME §11.2.

--- 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 §11.2
 required_documents:
   - incorporation
   - beneficial_ownership
@@ -12,3 +12,11 @@
   - ofac_sdn
   - eu_consolidated
 agent_owner: kyb_agent
+match_usage_required: true
+match_usage_fee_usd: 5000
+match_inquiry_fee_applies: true
+match_mandates:
+  - add_terminated_merchants_when_circumstance_exists
+  - inquire_against_match_database
+match_compliance_expectation: "Diligent, reasonable, and good faith use per Mastercard standards"  
+# Updated to reflect Mastercard SPME §11.2 requirement for all Acquirers globally to actively use MATCH, including adding terminated Merchants and inquiry obligations, replacing prior optional use guidance.
--- a/policies/kyb_acquirer/policy.md
+++ b/policies/kyb_acquirer/policy.md
@@ -18,6 +18,13 @@
 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.
+5. Utilize the MATCH system as mandated by Mastercard by:
+   - Adding information about terminated merchants under defined circumstances.
+   - Inquiring against the MATCH database before onboarding and during monitoring.
+6. Document all verification outcomes and retain records for audit purposes.
 
-Source authority: Mastercard SPME §2.1.
+Halyard Pay must be aware of Mastercard’s annual MATCH usage fee and inquiry fees, and
+ensure compliance with all MATCH standards through diligent, reasonable, and good
+faith actions.
+
+Source authority: Mastercard SPME §2.1, §11.2.