program: Acquirer KYB
- authority: Mastercard SPME 2.1, 11.2.6
+ authority: Mastercard SPME 2.1, 11.2.6, 5
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.
+ #
+ # Additionally, per Mastercard SPME §5, the Acquirer must explicitly affirm that Restricted Transactions, including those defined under the Internet Gambling Policy, will not be submitted from the Merchant for authorization.
+ # Mastercard approval is required prior to processing any skill games Transactions for the Merchant, Sponsored Merchant, or other entity. This affirmation and approval step must be incorporated in merchant due diligence and registration processes.

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. Specifically confirm and document that the merchant will not submit Restricted Transactions as defined by Mastercard's Internet Gambling Policy.

5. Obtain explicit Mastercard approval before processing skill games transactions for the merchant or related entities.

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

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

6. 8. 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, 5, 9.4.5, 11.2.6.