program: Fraud Monitoring
authority: Mastercard SPME 2.8.6, 3.7, 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 focus on principal owners only; associate owners and Service Provider name reporting are excluded per SPME 11.1.1.
# Acquirers may search information on up to five principal owners per Merchant.
# Multiple data fields determine matches; MATCH supports editing and error correction to reduce delays.
# Retroactive alert processing supports data up to 360 days old.
# Acquirers control receipt and detail of inquiry match information.
# Real-time access is available via MATCH Online, API, and batch processing.
# Merchant URL information may be added and searched.
# Upon receiving MATCH inquiry results, acquirers must assess the need for further investigation or risk mitigation as updated in SPME.
#
# Per updated SPME 8.6.6, Mastercard adds Merchants to MATCH using reason code 24 (Illegal Transactions) when Merchants satisfy Coercion Program criteria.
- # Merchants subject to a new coercion claim within 120 calendar days will be added with reason code 00 (Questionable Acquirer/Under Investigation).
+ # Merchants subject to a new coercion claim within a continuous 120 calendar day review period around the alleged event date (60 days before and 60 days after) will be added with reason code 00 (Questionable Acquirer/Under Investigation).
# If confirmed to meet Coercion Program criteria, the MATCH record updates to reason code 24; if not, the record is deleted.
- # The definition of the 120 calendar day review period for coercion investigations is now a continuous 120-day window from the alleged event date without the previous specific 60-day split or discretionary expansion.
+ # This continuous 120-day window replaces prior splits or discretionary expansions.
+ # The definition of the investigation timeframe reflects Mastercard's sole discretion in extending this period.
#
# Per SPME 11.1.1, acquirers must submit incident reports to Mastercard Fraud Control Programs when violations go unreported by the Acquirer's MMSP, enhancing reporting rigor.

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, per Mastercard's investigation timelines; records must be updated or removed based on confirmation of these claims.

- Note the investigation period for alleged coercion claims spans 60 days before and 60 days after the first alleged coerced transaction, totaling 120 calendar days, which Mastercard may extend at its discretion. This affects the timing and scope of fraud reviews.

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, §8.6.2, §8.6.6, §11.1.1, and §11.