Halyard Pay · Policy Updates Powered by Carver Agents

Mastercard SPME §9.4.1 · May 2023 → Sep 2023

Non-face-to-face Adult Content and Services Merchants

substantive
⚠ Extraction warning — review against source PDF. One side of the Mastercard SPME text below appears to contain only the page-running header, not body content. This usually means the section heading fell on a page boundary and the body was attributed to a neighbouring section in the source PDF. The AI summary and proposed edit below may be misleading. Verify in: May 2023 · page 103 ↗ · Sep 2023 · page 95 ↗.

The updated rules require Merchants to allow individuals depicted in content to appeal for its removal and establish consent. Merchants must report flagged content and complaints monthly to Acquirers, who share with Mastercard. Merchants must not use illegal adult content to attract users, implement anti-trafficking policies, and provide Acquirers temporary site access for review upon request.

Sources Mastercard SPME · May 2023 · page 103 PDF Mastercard SPME · Sep 2023 · page 95 PDF Content Moderation current
Also in §9.x this release substantive §9.2 General Registration Requirements substantive §9.3 General Monitoring Requirements substantive §9.4.5 Skill Games Merchants substantive §9.4.8 High-Risk Securities Merchants substantive §9.4.9 Cryptocurrency Merchants
Why these edits? The updated rules in section 9.4.1 impose new obligations on Merchants to manage flagged adult content, provide monthly reporting to Acquirers (and Mastercard upon request), and enable content appeal/removal processes, which aligns with the Content Moderation (BRAM Brand Integrity) policy referencing section 10.5 closely related to content standards and moderation requirements.
Mastercard SPME §9.4.1
This section was substantively restructured between versions (5% text overlap). Compare the texts directly below.
Before · May 2023 · page 103

Security Rules and Procedures—Merchant Edition • 7 February 2023

After · Sep 2023 · page 95

Security Rules and Procedures—Merchant Edition • 1 August 2023

reported complaints within seven (7) business days. In the event that such review yields evidence of illegal content, the Merchant must remove that content immediately.

  1. The Merchant must offer the ability for any person depicted in a video or other content to appeal to remove such content. Once triggered, the Merchant must, through a reasonable process, confirm that the appropriate consent was obtained, including as required above. If consent cannot be established, or if the person depicted in the content can demonstrate that the consent is void under applicable law, the Merchant must remove the content with immediate effect. If the Merchant disagrees that consent is void under applicable law, the Merchant must allow such disagreement to be resolved by a neutral body, at the Merchant’s expense.
  2. The Merchant must provide its Acquirer with monthly reports that include a list of all content, including URLs and videos, flagged as potentially illegal or otherwise in violation of the Standards and the relevant actions taken by the Merchant, as well as details of all complaints and take-down requests the Merchant received. The Acquirer must share these reports with Mastercard, upon request.
  3. The Merchant must not attract users to its website by utilizing adult content that is illegal or otherwise violates the Standards.
  4. The Merchant must have effective policies in place that prohibit the use of its website in any way that promotes or facilitates human trafficking, sex trafficking or physical abuse. Active membership and participation in an anti-human trafficking and/or anti-child exploitation organization is highly recommended.
  5. Upon request, the Acquirer must be able to provide Mastercard with temporary account credentials that allow access to a Merchant website for up to seven (7) days to view all content that is behind a paywall or otherwise restricted to members of the website.
Halyard Pay · 2 files
program: Content Moderation (BRAM)


- authority: Mastercard SPME §10.5


+ authority: Mastercard SPME §10.5 and §9.4.1


prohibited_categories:


  - counterfeit_goods


  - illegal_drugs


  - adult_content_violations


  - intellectual_property_violations


  - gambling_in_restricted_jurisdictions


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 reflect Mastercard SPME §9.4.1 enhancements which require Merchants to manage flagged adult content with timely removal when consent issues arise, provide monthly detailed reports of potentially illegal content and complaints to Acquirers (and Mastercard upon request), and maintain appeal processes for content removal.


+ # This supplements existing prohibitions and review cadence described under §10.5, emphasizing Merchant accountability and transparency in adult content moderation.


+ # Removed outdated Merchant registration and MCC/TCC-based identification specifics previously present but no longer required.

Content Moderation (BRAM Brand Integrity)

Mastercard's Business Risk Assessment and Mitigation (BRAM) program includes specific ¶ brand-integrity provisions that prohibit prohibiting acquirers from processing transactions for merchants engaged in activities that violate violating Mastercard's acceptable use standards. Halyard Pay monitors merchant storefront content and transaction data to identify and remediate prohibited content, including adult content, and takes action to enforce compliance. content and content violating laws or Mastercard's Standards.

Prohibited categories

Merchants found to be selling or facilitating counterfeit goods, illegal drugs, adult ¶ content that violates applicable law, goods or services that infringe unlawful adult content, intellectual property rights, infringement, or gambling services in restricted jurisdictions where such services are ¶ restricted are subject to immediate review and, and if confirmed, merchant and possible suspension.

Required actions

  1. Review merchant storefront content on a weekly cadence using automated scanning ¶ combined with periodic and manual sampling. methods.

  2. Flag any merchant whose content matches a merchants with content matching prohibited category categories 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 steps.

5. Ensure merchants comply with updated requirements to manage flagged adult content, including timely content removal upon verified complaints, providing monthly reports to Acquirers on flagged content and actions in the BRAM case file. taken, and enabling appeal processes for content removal as detailed in Mastercard SPME §9.4.1.

6. Support Acquirers in obtaining temporary access to restricted merchant content if needed.

Note: Mastercard's SPME has removed specific prior MCC and Transaction Category Code (TCC) ¶ requirements and the registration requirement mandates for non-face-to-face adult content transactions as outlined previously in but added detailed obligations on content management and reporting under 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. aligns with these updates, emphasizing merchant responsibility for lawful, consented adult content and proactive reporting.

Source authority: Mastercard SPME §10.5.§§9.4.1, 10.5.

policies/content_moderation/policy.md — after applying change

Content Moderation (BRAM Brand Integrity)

Mastercard's Business Risk Assessment and Mitigation (BRAM) program includes specific ¶ brand-integrity provisions that prohibit prohibiting acquirers from processing transactions for merchants engaged in activities that violate violating Mastercard's acceptable use standards. Halyard Pay monitors merchant storefront content and transaction data to identify and remediate prohibited content, including adult content, and takes action to enforce compliance. content and content violating laws or Mastercard's Standards.

Prohibited categories

Merchants found to be selling or facilitating counterfeit goods, illegal drugs, adult ¶ content that violates applicable law, goods or services that infringe unlawful adult content, intellectual property rights, infringement, or gambling services in restricted jurisdictions where such services are ¶ restricted are subject to immediate review and, and if confirmed, merchant and possible suspension.

Required actions

  1. Review merchant storefront content on a weekly cadence using automated scanning ¶ combined with periodic and manual sampling. methods.

  2. Flag any merchant whose content matches a merchants with content matching prohibited category categories 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 steps.

5. Ensure merchants comply with updated requirements to manage flagged adult content, including timely content removal upon verified complaints, providing monthly reports to Acquirers on flagged content and actions in the BRAM case file. taken, and enabling appeal processes for content removal as detailed in Mastercard SPME §9.4.1.

6. Support Acquirers in obtaining temporary access to restricted merchant content if needed.

Note: Mastercard's SPME has removed specific prior MCC and Transaction Category Code (TCC) ¶ requirements and the registration requirement mandates for non-face-to-face adult content transactions as outlined previously in but added detailed obligations on content management and reporting under 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. aligns with these updates, emphasizing merchant responsibility for lawful, consented adult content and proactive reporting.

Source authority: Mastercard SPME §10.5.§§9.4.1, 10.5.

Source authority: Mastercard SPME §9.4.1.

--- a/policies/content_moderation/rules.yaml
+++ b/policies/content_moderation/rules.yaml
@@ -1,5 +1,5 @@
 program: Content Moderation (BRAM)
-authority: Mastercard SPME §10.5
+authority: Mastercard SPME §10.5 and §9.4.1
 prohibited_categories:
   - counterfeit_goods
   - illegal_drugs
@@ -12,5 +12,6 @@
 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 reflect Mastercard SPME §9.4.1 enhancements which require Merchants to manage flagged adult content with timely removal when consent issues arise, provide monthly detailed reports of potentially illegal content and complaints to Acquirers (and Mastercard upon request), and maintain appeal processes for content removal.
+# This supplements existing prohibitions and review cadence described under §10.5, emphasizing Merchant accountability and transparency in adult content moderation.
+# Removed outdated Merchant registration and MCC/TCC-based identification specifics previously present but no longer required.

--- a/policies/content_moderation/policy.md
+++ b/policies/content_moderation/policy.md
@@ -1,32 +1,20 @@
 # 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.
+Mastercard's Business Risk Assessment and Mitigation (BRAM) program includes provisions prohibiting acquirers from processing transactions for merchants engaged in activities violating Mastercard's acceptable use standards. Halyard Pay monitors merchant storefront content and transaction data to identify and remediate prohibited content, including adult content and content violating laws or Mastercard's Standards.
 
 ## 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.
+Merchants selling or facilitating counterfeit goods, illegal drugs, unlawful adult content, intellectual property infringement, or gambling services in restricted jurisdictions are subject to immediate review and possible 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.
+1. Review merchant storefront content weekly using automated and manual methods.
+2. Flag merchants with content matching prohibited categories for human review within one business day.
+3. Suspend processing privileges if prohibited content is confirmed.
+4. Document all findings and remediation steps.
+5. Ensure merchants comply with updated requirements to manage flagged adult content, including timely content removal upon verified complaints, providing monthly reports to Acquirers on flagged content and actions taken, and enabling appeal processes for content removal as detailed in Mastercard SPME §9.4.1.
+6. Support Acquirers in obtaining temporary access to restricted merchant content if needed.
 
-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.
+Note: Mastercard's SPME has removed prior MCC and Transaction Category Code requirements and registration mandates for non-face-to-face adult content transactions but added detailed obligations on content management and reporting under section 9.4.1. Halyard Pay's content moderation aligns with these updates, emphasizing merchant responsibility for lawful, consented adult content and proactive reporting.
 
-Source authority: Mastercard SPME §10.5.+Source authority: Mastercard SPME §§9.4.1, 10.5.