program: Acquirer KYB
- authority: Mastercard SPME 2.1, 11.2.3, 11.2.6
+ authority: Mastercard SPME 2.1, 8.6.7, 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 §8.6.7, acquirers must require Merchants to complete a Coercion Program FMP questionnaire if the Merchant has been identified in two or more coercion events within 12 months, or must require it after three or more identifications within 18 months. This questionnaire assists in escalation decisions regarding potential onsite FMP reviews as part of enhanced KYB due diligence obligations.

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

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. Require completion of a Coercion Program FMP questionnaire from Merchants who have two or more Coercion Program identifications within a 12-month period, and mandate it for those with three or more identifications within an 18-month period. Responses to this questionnaire will aid in escalation decisions, potentially prompting an on-site FMP review.

Source authority: Mastercard SPME §§2.1, 7.1, 8.6.7, 11.2.3, 11.2.6.