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Education

with a torrent of AI-generated websites and reviews
promoting a given payments solution, does the supplier
of that solution have a duty to disclose to the merchant
that the various websites and reviews are all from a
single source: their AI-driven-marketing department.

Dishonest merchants with superpowers
In recent years, payment processors have taken on
ever more responsibility for the wrongdoings of the
merchants they serve. In the pre-AI world, merchants
rise and fall in volume as a function of their ability to
market their services. Imagine, however, a merchant
that harnesses AI to "tickle" the consumer in just the
right way for them to part with their money quickly
but fraudulently.

ISOs and processors are familiar with all manner of
high-volume merchants that have questionable ethics.
AI gives those merchants super-powers. The ISO may
be called upon by their acquiring bank and possibly
regulators, such as the Federal Trade Commission to
police those merchants.

The marketing tools that merchants will have will
perhaps be so powerful and so quickly deployed that
processor underwriting departments do not have tools
necessary to manage the risks. ISOs should perhaps
look over the horizon into a processing landscape
where AI-powered underwriting tools are necessary to
nip fraud in the bud—at scale.
Shrinking salesperson

It's already hard to believe a lot of the spam and texts
we receive. AI will enable bots to make sales calls and
sound believable. This may put the actual sales rep in
a position of having to compete with machines in sales
calls. It's hard to tell whether the flood of bot pitches
will make real, sometimes called "bio" salespeople
more or less attractive to merchants.

Another inversion of reality is that merchants might
prefer to deal with machines than people—finding the
machines more believable.

I remain optimistic about our future provided we
prepare for a reshuffling of the deck in terms of
which skills are most valued in advancing a payments
business. With laws and courts answering to a human
standard, there is room for optimism that humans
will remain an important part of the sale of payment
services.

In publishing The Green Sheet, neither the author nor the publisher
are engaged in rendering legal, accounting, or other professional
services. If legal advice or other expert assistance is required, the
services of a competent professional should be sought. For further
information on this article, please contact Adam Atlas, Attorney at
Law email: atlas@adamatlas.com, Tel. 514-842-0886.
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