program: Content Moderation (BRAM)
- authority: Mastercard SPME §10.5
+ authority: Mastercard SPME §10.5, §5.11.7
prohibited_categories:
  - counterfeit_goods
  - illegal_drugs
  - adult_content_violations
  - intellectual_property_violations
  - gambling_in_restricted_jurisdictions
+   - illegal_or_brand_damaging_transactions
review_cadence: weekly
human_review_trigger_business_days: 1
confirmed_violation_action: suspend_processing
case_documentation_required: true
agent_owner: content_mod_agent
 
- # Removed specific references to non-face-to-face adult content transaction identification by MCC/TCC and Merchant registration requirements, reflecting Mastercard SPME §9.4.1 update which eliminates these obligations for Acquirers.
- # Policy focuses on broader content moderation enforcement consistent with active SPME sections.
+ # Updated to include prohibition on illegal or brand-damaging transactions as per Mastercard SPME §5.11.7, strengthening brand integrity enforcement in content moderation.

Content Moderation (BRAM Brand Integrity)

Mastercard's Business Risk Assessment and Mitigation (BRAM) program includes specific

brand-integrity provisions that prohibit acquirers from processing transactions for

merchants engaged in activities that violate Mastercard's acceptable use standards.

Halyard Pay monitors merchant storefront content and transaction data to identify prohibited

content, including adult content, and takes action to enforce compliance.

Prohibited categories

Merchants found to be selling or facilitating counterfeit goods, illegal drugs, adult

content that violates applicable law, goods or services that infringe intellectual

property rights, or gambling services in jurisdictions where such services are

restricted are subject to immediate review and, and if confirmed, merchant suspension.

Required actions

1. Review merchant storefront content on a weekly cadence using automated scanning

combined with periodic manual sampling.

2. Flag any merchant whose content matches a prohibited category for human review

within one business day.

3. Suspend the merchant's processing privileges pending investigation if prohibited

content is confirmed.

4. Document all findings and remediation actions in the BRAM case file.

## Alignment with Mastercard Illegal or Brand-Damaging Transactions Rule

In addition to the BRAM program requirements, Halyard Pay also adheres to Mastercard's

Illegal or Brand-damaging Transactions Rule (SPME §5.11.7), which reinforces the

obligation to prevent processing for merchants whose activities risk harm to the

Mastercard brand or involve illegal goods or services. This requires enhanced

monitoring and prompt remediation efforts consistent with content moderation standards.

Note: Mastercard's SPME has removed specific MCC and Transaction Category Code (TCC)

requirements and the registration requirement for non-face-to-face adult content

transactions as outlined previously in section 9.4.1. Halyard Pay's content moderation

focuses on merchant content evaluation and remediation rather than transaction coding

and registration of adult content merchants.

Source authority: Mastercard SPME §10.5.§§5.11.7, 10.5.