program: Fraud Monitoring
authority: Mastercard SPME §3.7, §8.6.6, §11.1.1
fraud_to_sales_ratio_threshold: 0.015
min_count_per_month: 100
monitoring_cadence: monthly
escalation_actions:
  - escalate_to_human_review
  - notify_acquirer
+   - provide_incident_report_to_mastercard_fraud_control_programs  # Added to meet new SPME requirements
lookback_period_months: 1
remediation_review_interval_days: 30
agent_owner: fraud_ops_agent
 
# MATCH fraud detection features are limited to principal owners only; associate owners and Service Provider name reporting are removed per SPME §11.1.1.
# Acquirers may add and search for information on up to five principal owners per Merchant.
# Multiple data fields are used to determine matches; MATCH supports editing and error notification to reduce delays.
# Retroactive alert processing is supported for data up to 360 days old.
# Acquirers control receipt and detail of inquiry match information.
# Real-time access via MATCH Online and API, and batch operations remain available.
# Merchant URL information may be added and searched.
# After obtaining MATCH inquiry results, acquirers must assess whether further investigation or risk mitigation actions are warranted, per updated SPME requirements.
#
# New requirements under SPME §8.6.6 specify that Mastercard will add Merchants to MATCH using reason code 24 (Illegal Transactions) when Merchants meet Coercion Program criteria.
# Merchants subject to a subsequent claim of coercion within 12 months will be added with reason code 00 (Questionable Acquirer/Under Investigation).
# If the claim is confirmed to meet Coercion Program criteria, the MATCH record will be updated to reason code 24.
# If not confirmed, the MATCH record will be deleted.
# These provisions enhance fraud monitoring by requiring tracking of coercion-related transaction risks.
+ #
+ # New SPME §11.1.1 further requires acquirers to submit incident reports to Mastercard Fraud Control Programs when violations are not reported by the Acquirer's MMSP, strengthening incident response and reporting cadence.
+ 

Fraud Monitoring

Halyard Pay monitors merchant fraud activity and leverages Mastercard's MATCH system for enhanced fraud risk assessment on merchants processed through our platform.

When this policy applies

This policy applies to all merchants processed by Halyard Pay where Mastercard is the applicable network, covering both card-present and card-not-present transactions.

Required actions

1. Compute the merchant's rolling fraud-to-sales ratio each calendar month.

2. If the ratio meets or exceeds 1.5% and the fraud count reaches at least 100 transactions in that month, escalate the merchant account to human review immediately.

3. Utilize Mastercard's MATCH system data focusing on principal owners only, as per the updated Mastercard SPME guidelines. Do not consider associate owners or Service Provider names in fraud assessments.

4. Maintain awareness of Mastercard's MATCH reason codes related to coercion programs: merchants may be added with reason code 24 for illegal transactions upon meeting coercion criteria, or with code 00 if a subsequent coercion claim arises within 12 months; records must be updated or removed based on confirmation of these claims.

5. After accessing MATCH data, conduct a risk assessment to determine whether further investigation or additional measures are warranted.

6. Notify the acquiring compliance officer and document the case ID with supporting transaction data.

7. Track case progress until the account returns to threshold compliance or is terminated.

8. If any fraud violation is detected but not reported by Halyard Pay as the Acquirer's MMSP, escalate the incident report to Mastercard's Fraud Control Programs in accordance with Mastercard SPME §11 protocols.

Source authority: Mastercard SPME §3.7, §8.6.6, and §11.1.1.§11.1.1, and §11.