Mastercard SPME §8.4 · Sep 2023 → Feb 2024

Questionable Merchant Audit Program (QMAP)

substantive

The criteria for identifying Questionable Merchants have been expanded to include specific rules for Brazil, requiring certain fraud thresholds and transaction types during a 120-day investigation period. Other original criteria remain, with some minor formatting and punctuation changes.

Sources Mastercard SPME · Sep 2023 · page 79 PDF Mastercard SPME · Feb 2024 · page 77 PDF Fraud Monitoring current
Also in §8.x this release breaking §8.6.5 Chargeback Responsibility substantive §8.4.2 Mastercard Commencement of an Investigation substantive §8.4.3 of this manual, or substantive §8.4.6 Mastercard Determination substantive §8.4.8 Fraud Recovery substantive §8.6 Coercion Program substantive §8.6.1 Issuer Submissions substantive §8.6.2 Investigation Process substantive §8.6.7 Franchise Management Program (FMP) Questionnaire-based Review substantive §8.7.1 Definitions substantive §8.7.3 Mastercard Notification to Acquirers substantive §8.8 Business Risk Assessment and Mitigation (BRAM) Program substantive §8.8.1 BRAM Investigation Process substantive §8.8.2 Acquirer Response Requirements substantive §8.8.4 Noncompliance Assessment Mitigation substantive §8.9 Merchant Monitoring Program (MMP) substantive §8.9.1 MMP Participation Requirements
Why these edits? The addition of specific fraud threshold criteria and transaction types for Brazil under the Questionable Merchant Audit Program expands fraud monitoring obligations to include regional rules, particularly a higher fraud-to-sales ratio and specific transaction authentication requirements.
Mastercard SPME §8.4
Security Rules and Procedures—Merchant Edition • 1 August 2023 6 February 2024 f. No payment has been made of charges to the account; or g. The Issuer closed the account after a failed payment (dishonored check or the like) of charges to the account. Case Scope Period means the 120-calendar-day period preceding the date on which Mastercard commences an investigation into the activities of a suspected Questionable Merchant. Questionable Merchant means a Merchant that satisfies all of the following criteria: 1. The Merchant submitted at least USD 50,000 in Transaction volume during the Case Scope Period; 2. The Merchant submitted at least five (5) Transactions to one or more Acquirers during the Case Scope Period; and 3. At least fifty (50) percent of the Merchant’s Merchant's total Transaction volume involved the use of Cardholder bust-out accounts OR At least three (3) of the following four (4) conditions apply to the Merchant’s Merchant's Transaction activity during the Case Scope Period: a. The Merchant’s Merchant's fraud-to-sales Transaction ratio was seventy (70) percent or greater. b. At least twenty (20) percent of the Merchant’s Merchant's Transactions submitted for authorization were declined by the Issuer or received a response of “01—Refer to issuer” "01-Refer to issuer" during the Case Scope Period. c. The Merchant has been submitting Transactions for fewer than six (6) months. d. The Merchant’s Merchant's total number or total dollar amount of fraudulent Transactions, authorization declines, and Issuer referrals was greater than the Merchant’s Merchant's total number or total dollar amount of approved Transactions. OR For the country of Brazil: a. Case scope period: 120 calendar days preceding the date Mastercard commences an investigation into the activities of a suspected Merchant; b. Card-present Transactions (POS entry mode 05 or 07) and CNP Transactions (POS entry modes 10 and 81) that are 3DS fully-authenticated; c. Minimum of BRL 100,000 in fraudulent Transactions reported per Acquirer under fraud type 56 (within the case scope period); d. The Merchant's fraud to sales ratio was seventy-five percent (75%) or higher based on fraud reported under the code "56-Manipulation of Cardholder." NOTE: Transaction activity (“on-us” "on-us" or otherwise) that is not processed through Mastercard systems is not considered in determining whether a Merchant meets the criteria of a Questionable Merchant. Mastercard has sole discretion, based on information from any source, to determine whether a Merchant meeting these criteria is a Questionable Merchant. Mastercard Fraud Control Programs
Halyard Pay · 2 files
program: Fraud Monitoring
- authority: Mastercard SPME §3.7, §8.6.6, §11.1.1
+ authority: Mastercard SPME 2.4, 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
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.
+ # MATCH fraud detection features remain limited to principal owners as per updated SPME 11.1.1 guidance.
+ # Acquirers may continue to add and query up to five principal owners per Merchant, with multiple data fields employed for accurate matching.
+ # MATCH supports editing and error notification functionality to optimize processing timelines, with retroactive alerts permitted for data up to 360 days old.
+ # Acquirers retain control of inquiry match data access and detail level.
+ # Merchant URL reporting and searching is supported.
+ # Following MATCH inquiries, assessment of further investigation or risk mitigation is mandatory, in compliance with SPME directives.
#
- # 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.
+ # SPME 8.6.6 introduces mandates for Mastercard to add Merchants to MATCH using reason code 24 for illegal transactions tied to coercion programs. Merchants linked to coercion claims within 12 months are flagged with reason code 00 initially, updated to 24 on confirmation, or deleted if unconfirmed.
+ # This bolsters fraud monitoring through enhanced tracking of coercion-related fraud exposures.
+ #
+ # Importantly, SPME 2.4 adds a new regional definition of "Questionable Merchant" specific to Brazil, with criteria including:
+ # - Minimum BRL 100,000 in 3DS fully-authenticated fraud transactions per Acquirer under fraud type 56 within the 120-day case scope period;
+ # - Fraud-to-sales ratio threshold increased to 75% for fraud type "56-Manipulation of Cardholder";
+ # - Inclusion of both card-present (POS entry mode 05 or 07) and CNP (POS entry mode 10 or 81) transactions;
+ # - Base case scope period remains 120 calendar days prior to Mastercard investigation date.
+ #
+ # The program incorporates these regional fraud identification criteria alongside the global metrics to ensure comprehensive monitoring coverage.
+

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. Consider additional regional criteria, specifically for Brazil, where higher fraud-to-sales ratios (75% or greater based on fraud type 56) and authentication conditions for transactions apply to identifying questionable merchants, pursuant to Mastercard SPME §8.4.

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

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

Source authority: Mastercard SPME §3.7, §8.4, §8.6.6, and §11.1.1.

policies/fraud_monitoring/policy.md — after applying change

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. Consider additional regional criteria, specifically for Brazil, where higher fraud-to-sales ratios (75% or greater based on fraud type 56) and authentication conditions for transactions apply to identifying questionable merchants, pursuant to Mastercard SPME §8.4.

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

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

Source authority: Mastercard SPME §3.7, §8.4, §8.6.6, and §11.1.1.

Source authority: Mastercard SPME §8.4.

--- a/policies/fraud_monitoring/rules.yaml
+++ b/policies/fraud_monitoring/rules.yaml
@@ -1,5 +1,5 @@
 program: Fraud Monitoring
-authority: Mastercard SPME §3.7, §8.6.6, §11.1.1
+authority: Mastercard SPME 2.4, 3.7, 8.6.6, 11.1.1
 fraud_to_sales_ratio_threshold: 0.015
 min_count_per_month: 100
 monitoring_cadence: monthly
@@ -10,17 +10,21 @@
 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.
+# MATCH fraud detection features remain limited to principal owners as per updated SPME 11.1.1 guidance.
+# Acquirers may continue to add and query up to five principal owners per Merchant, with multiple data fields employed for accurate matching.
+# MATCH supports editing and error notification functionality to optimize processing timelines, with retroactive alerts permitted for data up to 360 days old.
+# Acquirers retain control of inquiry match data access and detail level.
+# Merchant URL reporting and searching is supported.
+# Following MATCH inquiries, assessment of further investigation or risk mitigation is mandatory, in compliance with SPME directives.
 #
-# 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.+# SPME 8.6.6 introduces mandates for Mastercard to add Merchants to MATCH using reason code 24 for illegal transactions tied to coercion programs. Merchants linked to coercion claims within 12 months are flagged with reason code 00 initially, updated to 24 on confirmation, or deleted if unconfirmed.
+# This bolsters fraud monitoring through enhanced tracking of coercion-related fraud exposures.
+#
+# Importantly, SPME 2.4 adds a new regional definition of "Questionable Merchant" specific to Brazil, with criteria including:
+# - Minimum BRL 100,000 in 3DS fully-authenticated fraud transactions per Acquirer under fraud type 56 within the 120-day case scope period;
+# - Fraud-to-sales ratio threshold increased to 75% for fraud type "56-Manipulation of Cardholder";
+# - Inclusion of both card-present (POS entry mode 05 or 07) and CNP (POS entry mode 10 or 81) transactions;
+# - Base case scope period remains 120 calendar days prior to Mastercard investigation date.
+#
+# The program incorporates these regional fraud identification criteria alongside the global metrics to ensure comprehensive monitoring coverage.
+

--- a/policies/fraud_monitoring/policy.md
+++ b/policies/fraud_monitoring/policy.md
@@ -13,7 +13,8 @@
 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.
+6. Consider additional regional criteria, specifically for Brazil, where higher fraud-to-sales ratios (75% or greater based on fraud type 56) and authentication conditions for transactions apply to identifying questionable merchants, pursuant to Mastercard SPME §8.4.
+7. Notify the acquiring compliance officer and document the case ID with supporting transaction data.
+8. Track case progress until the account returns to threshold compliance or is terminated.
 
-Source authority: Mastercard SPME §3.7, §8.6.6, and §11.1.1.
+Source authority: Mastercard SPME §3.7, §8.4, §8.6.6, and §11.1.1.