Mastercard SPME §11.2.2 · Sep 2023 → Feb 2024

When to Add a Merchant to MATCH

substantive

The requirement now explicitly mandates Acquirers to add merchant information to MATCH within five calendar days if termination occurs and suspicious conditions exist, replacing a previous note about record retention and adding a compliance timeframe and conditions for updates.

Sources Mastercard SPME · Sep 2023 · page 134 PDF Mastercard SPME · Feb 2024 · page 134 PDF KYB Acquirer current

Also in §11.x this release substantive §11 If the Acquirer is currently participating in the Merchant Monitoring Program, and this substantive §11.2.3 Inquiring about a Merchant substantive §11.5 MATCH Reason Codes substantive §11.5.1 Reason Codes for Merchants Listed by the Acquirer substantive §11.7.1 Privacy and Data Protection

Why these edits? The new requirement mandates Acquirers to add merchant information to MATCH within five calendar days if termination and suspicious conditions exist, which relates to Acquirer KYB obligations in monitoring merchant risk and complying with record updates as per section 2.1.

Mastercard SPME §11.2.2

This section was substantively restructured between versions (5% text overlap). Compare the texts directly below.

Before · Sep 2023 · page 134

Security Rules and Procedures—Merchant Edition • 1 August 2023

NOTE: The MATCH system database stores inquiry records for 360 days.

After · Feb 2024 · page 134

If either the Acquirer or the Merchant acts to terminate the acquiring relationship (such as by giving notice of termination) and, at the time of that act, the Acquirer has reason to believe that a condition described in Table 11.4 exists, then the Acquirer must add the required information to MATCH within five calendar days of the earlier of either: 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

Halyard Pay · 2 files

KYB Acquirer · rules.yaml

program: Acquirer KYB
- authority: Mastercard SPME 2.1, 11.2.3, 11.2.6
+ authority: Mastercard SPME 2.1, 11.2.2, 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
# 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.
+ # Additionally, per Mastercard SPME §11.2.2, if the Acquirer or Merchant terminates the acquiring relationship and the Acquirer reasonably suspects any condition in Table 11.4, the Acquirer must update the MATCH system with the required information within five calendar days of termination action to maintain compliance and accurate risk monitoring.

KYB Acquirer · policy.md

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

Collect all required KYB documents at onboarding prior to approval.
Conduct AML screening against applicable watchlists before approval.
Verify business licenses for regulated merchant categories.
Schedule a full re-verification review at least once every 365 days.
Document all verification outcomes and retain records for audit purposes.
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.
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.

8. If the acquiring relationship with a merchant is terminated and Halyard Pay has reason to suspect conditions that require notification under Mastercard's criteria (see Table 11.4 of SPME), Halyard Pay must submit the required information to the MATCH system within five calendar days of the termination or suspicion event, whichever is earlier.

Source authority: Mastercard SPME §§2.1, 7.1, 11.2.3, ~~11.2.6.~~11.2.6, 11.2.2.

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

Collect all required KYB documents at onboarding prior to approval.
Conduct AML screening against applicable watchlists before approval.
Verify business licenses for regulated merchant categories.
Schedule a full re-verification review at least once every 365 days.
Document all verification outcomes and retain records for audit purposes.
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.
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, 7.1, 11.2.3, ~~11.2.6.~~11.2.6, 11.2.2.

Source authority: Mastercard SPME §11.2.2.

--- a/policies/kyb_acquirer/rules.yaml
+++ b/policies/kyb_acquirer/rules.yaml
@@ -1,5 +1,5 @@
 program: Acquirer KYB
-authority: Mastercard SPME 2.1, 11.2.3, 11.2.6
+authority: Mastercard SPME 2.1, 11.2.2, 11.2.3, 11.2.6
 required_documents:
   - incorporation
   - beneficial_ownership
@@ -15,3 +15,4 @@
 # 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.
+# Additionally, per Mastercard SPME §11.2.2, if the Acquirer or Merchant terminates the acquiring relationship and the Acquirer reasonably suspects any condition in Table 11.4, the Acquirer must update the MATCH system with the required information within five calendar days of termination action to maintain compliance and accurate risk monitoring.
--- a/policies/kyb_acquirer/policy.md
+++ b/policies/kyb_acquirer/policy.md
@@ -21,5 +21,6 @@
 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.
+8. If the acquiring relationship with a merchant is terminated and Halyard Pay has reason to suspect conditions that require notification under Mastercard's criteria (see Table 11.4 of SPME), Halyard Pay must submit the required information to the MATCH system within five calendar days of the termination or suspicion event, whichever is earlier.
 
-Source authority: Mastercard SPME §§2.1, 7.1, 11.2.3, 11.2.6.+Source authority: Mastercard SPME §§2.1, 7.1, 11.2.3, 11.2.6, 11.2.2.