Halyard Pay · Policy Updates Powered by Carver Agents

Mastercard SPME §11.2.3 · May 2023 → Sep 2023

Inquiring about a Merchant

substantive

The updated rule mandates Acquirers to check the MATCH system before signing a Merchant Agreement or enabling transaction acceptance. Failure to do so under the correct Member ID/ICA Number can lead to compliance violations and assessments, emphasizing stricter enforcement and reporting accuracy.

Sources Mastercard SPME · May 2023 · page 146 PDF Mastercard SPME · Sep 2023 · page 134 PDF KYB Acquirer current
Also in §11.x this release breaking §11.4 Merchant Removal from MATCH substantive §11.1 MATCH Overview substantive §11.1.2 How does MATCH search when conducting an inquiry? substantive §11.2.1 Certification substantive §11.5 MATCH Reason Codes substantive §11.5.1 Reason Codes for Merchants Listed by the Acquirer
Why these edits? The update to section 11.2.3 emphasizes that Acquirers must check the MATCH system before entering into Merchant Agreements or enabling transaction acceptance, reinforcing the obligation to comply with Know Your Business (KYB) verification processes under the proper Member ID/ICA Number to avoid compliance violations and assessments.
Mastercard SPME §11.2.3
This section was substantively restructured between versions (1% text overlap). Compare the texts directly below.
Before · May 2023 · page 146

Security Rules and Procedures—Merchant Edition • 7 February 2023

matchhelp@mastercard.com. Such request must include the following information:

After · Sep 2023 · page 134

An Acquirer must check MATCH before signing an agreement with a Merchant and/or enabling a Merchant to accept Transactions, in accordance with section 7.1 of this manual. An Acquirer that enters into a Merchant Agreement without first submitting an inquiry to MATCH about the Merchant may be subject to an unfavorable ruling in a compliance case filed by a subsequent Acquirer of that Merchant. Acquirers must conduct inquiries under the proper Member ID/ICA Number for reporting compliance reasons. If an Acquirer does not conduct the inquiry under the proper Member ID/ICA Number (that is, the Member ID/ICA Number that is actually processing for the Merchant), Mastercard may find the Acquirer in noncompliance and may impose an assessment. Failure to comply with either the requirement of adding a terminated Merchant or inquiring about a Merchant may result in noncompliance assessments as described in Table 11.3.

Halyard Pay · 2 files
program: Acquirer KYB


- authority: Mastercard SPME 2.1, 11.2.6


+ authority: Mastercard SPME 2.1, 11.2.3, 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.


+ # Acquirers must perform a MATCH inquiry prior to entering into any Merchant Agreement or enabling a Merchant to accept transactions, as detailed in Mastercard SPME §11.2.3. This inquiry must be conducted using the correct Member ID/ICA Number associated with the Merchant to ensure proper compliance reporting.


+ # Failure to adhere to these requirements may result in noncompliance assessments.


+ # The Acquirer is also required to retain all MATCH records related to any Merchant, Sponsored Merchant, or ATM owner for a minimum of two years post-agreement termination, as per Mastercard SPME §11.2.6.

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.

7. Before entering into a Merchant Agreement or enabling a Merchant to accept transactions, Halyard Pay must conduct a MATCH inquiry using the proper Member ID/ICA Number assigned to Halyard Pay to ensure compliance. Failure to perform this check or to use the correct Member ID/ICA may result in noncompliance and assessments by Mastercard.

Source authority: Mastercard SPME ��������2.1, §§2.1, 7.1, 11.2.3, 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.

7. Before entering into a Merchant Agreement or enabling a Merchant to accept transactions, Halyard Pay must conduct a MATCH inquiry using the proper Member ID/ICA Number assigned to Halyard Pay to ensure compliance. Failure to perform this check or to use the correct Member ID/ICA may result in noncompliance and assessments by Mastercard.

Source authority: Mastercard SPME ��������2.1, §§2.1, 7.1, 11.2.3, 11.2.6.

Source authority: Mastercard SPME §11.2.3.

--- a/policies/kyb_acquirer/rules.yaml
+++ b/policies/kyb_acquirer/rules.yaml
@@ -1,5 +1,5 @@
 program: Acquirer KYB
-authority: Mastercard SPME 2.1, 11.2.6
+authority: Mastercard SPME 2.1, 11.2.3, 11.2.6
 required_documents:
   - incorporation
   - beneficial_ownership
@@ -12,5 +12,6 @@
   - 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.+# Acquirers must perform a MATCH inquiry prior to entering into any Merchant Agreement or enabling a Merchant to accept transactions, as detailed in Mastercard SPME §11.2.3. This inquiry must be conducted using the correct Member ID/ICA Number associated with the Merchant to ensure proper compliance reporting.
+# Failure to adhere to these requirements may result in noncompliance assessments.
+# The Acquirer is also required to retain all MATCH records related to any Merchant, Sponsored Merchant, or ATM owner for a minimum of two years post-agreement termination, as per Mastercard SPME §11.2.6.

--- a/policies/kyb_acquirer/policy.md
+++ b/policies/kyb_acquirer/policy.md
@@ -20,5 +20,6 @@
 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.
+7. Before entering into a Merchant Agreement or enabling a Merchant to accept transactions, Halyard Pay must conduct a MATCH inquiry using the proper Member ID/ICA Number assigned to Halyard Pay to ensure compliance. Failure to perform this check or to use the correct Member ID/ICA may result in noncompliance and assessments by Mastercard.
 
-Source authority: Mastercard SPME 2.1, 11.2.6.+Source authority: Mastercard SPME §§2.1, 7.1, 11.2.3, 11.2.6.