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Insights and Expertise




        Mastercard's Scam                                       Visa and Mastercard are both increasing pressure on
                                                                      Networks sharpen focus on scam activity
        Merchant Monitoring                                     acquirers to identify scam-related merchant activity

                                                                earlier, but their newest monitoring programs emphasize
        Program (SMMP)                                          somewhat different risks.

                                                                Visa's Visa Acquirer Monitoring Program (VAMP)
        By Ken Musante                                          consolidates fraud and dispute monitoring into a
                                                                broader framework focused on identifying problematic
        Napa Payments and Consulting                            merchant behavior before excessive fraud or chargebacks
                                                                accumulate.
                  egardless of advances in system security,
                  scams  that  exploit  human  vulnerability  will   Mastercard's new Scam Merchant Monitoring Program
                  persist.  AI is accelerating both the scale and   (SMMP), scheduled to take effect in July 2026, focuses more
        R sophistication of these schemes, enabling more        specifically on scams involving consumer manipulation—
        convincing  deception  and  increasing  pressure  on  detec-  transactions  technically  authorized  by  cardholders but
        tion systems. At the same time, consumer complaints are   induced through deception.
        rising and regulators are taking a more aggressive stance.
        Increasingly, enforcement actions are not limited to the
        bad actors  themselves,  but  extend  to  the  payment  eco-  ioral metrics.  While these data points are not new, the
        system: processors, payfacs and service providers, where   required response is. When a merchant is flagged under
        there is evidence that warning signs were ignored or con-  SMMP criteria, the acquirer must initiate an investigation
        trols were insufficient.                                within 72 hours. If scam activity is confirmed, the acquirer
                                                                is required to take action, including potentially blocking
        For example, in 2025, Paddle.com agreed to a $5 million   the merchant from processing Mastercard transactions.
        settlement with the Federal Trade Commission over alle-  Acquirers must monitor and intervene early
        gations that it facilitated deceptive tech-support schemes
        targeting U.S. consumers.                               Additional scrutiny applies to newly onboarded mer-
                                                                chants with limited processing history, and acquirers are
        In a separate matter, Block agreed to pay a $40 million civ-  expected to incorporate network-provided intelligence,
        il penalty to the New York State Department of Financial   including issuer-reported fraud data and chargeback in-
        Services related to deficiencies in its anti-money launder-  dicators tied to scam activity. As with Visa's VAMP frame-
        ing and compliance controls tied to its Cash App platform.   work, Mastercard is reinforcing the expectation that ac-
        While they each have distinct fact patterns, both cases un-  quirers actively monitor and intervene, rather than relying
        derscore heightened expectations around fraud preven-   solely on downstream indicators of fraud. These changes
        tion and oversight.                                     present operational challenges. Manual monitoring alone

        Card networks also raise expectations                   is unlikely to be sufficient given the volume, speed and
                                                                complexity of emerging scam typologies.
        The card networks are responding in parallel. Visa recent-
        ly consolidated its fraud and dispute monitoring programs   Acquirers will need to leverage automated and AI-driven
        into the Visa Acquirer Monitoring Program (VAMP), en-   tools to augment human review and more effectively uti-
        hancing its ability to identify problematic merchant activ-  lize internal expertise.
        ity earlier in the lifecycle. The shift reflects Visa's position
        that acquirers should proactively identify high-risk mer-  The direction is clear: both regulators and card networks
        chants rather than react after significant fraud or charge-  are placing greater responsibility on the payment ecosys-
        back activity has occurred.                             tem to identify and disrupt scam activity earlier. Acquir-
                                                                ers must manage third parties accordingly. In many cases,
        Mastercard is taking a similar approach with the introduc-  this means protecting consumers even when transactions
        tion of its Scam Merchant Monitoring Program (SMMP),    are technically authorized but induced through decep-
        effective July 2026.                                    tion.
                                                                As founder of Humboldt Merchant Services, co-founder of Eureka
        SMMP is specifically designed to address scams involving   Payments, and a former executive for such payments innovators as
        consumer manipulation, where cardholders are induced    WePay, a division of JPMorgan Chase, Ken Musante has experience in
        to authorize transactions under false pretenses. This rep-  all aspects of successful ISO building. He currently provides consulting
        resents a meaningful shift from traditional fraud models   services and expert witness testimony as founder of Napa Payments
        that focus primarily on unauthorized transactions. Under   and Consulting, www.napapaymentsandconsulting.com. Contact him
        SMMP, acquirers are required to monitor merchant activ-  at  kenm@napapaymentsandconsulting.com, 707-601-7656 or  www.
        ity across a defined set of risk indicators, including trans-
        action volumes, fraud rates, chargebacks and other behav-  linkedin.com/in/ken-musante-us.
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