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Risk Management Requirements for Overseas Acquirers

These Risk Management Requirements apply to all Alipay overseas cooperative acquirers (“Overseas Acquirers”) having entered into an Alipay Service Contract (or functional equivalent contract for Alipay services) with Co. Ltd. or its affiliate (“Alipay”). This document sets out the Acquirer’s key responsibilities for managing risks associated with providing payment processing, authorization and settlement services to its Secondary Merchants and enabling its Secondary Merchants to accept Alipay Services indirectly through it.

All Overseas Acquirers must ensure that their business operations and its Secondary Merchants comply with these Risk Management Requirements.

Unless otherwise defined herein, capitalized terms used in this document have the meanings given to them in the Alipay Service Contract between the Overseas Acquirer and Alipay.

1. Overseas Acquirer’s Key Responsibilities

1) Secondary Merchant Onboarding

Overseas Acquirers must conduct Due Diligence on all prospective Secondary Merchants prior to onboarding including but not limited to the following:

a) Secondary Merchant Requirements

i. Overseas Acquirers must not onboard any Merchants who sell Prohibited Products specified in Annex I.

ii. Overseas Acquirers must only onboard Merchants with bona fide business purposes.

b) Secondary Merchant Information

i. Overseas Acquirers must provide or procure that the relevant Secondary Merchant provide complete and accurate information in relation to that Merchant as requested by Alipay including but not limited to:

Offline Secondary Merchants

Online Secondary Merchants

·         business name (registered and ‘trading as’ name)

·         registration number

·         Secondary Merchant type

·         country of incorporation

·         registered address

·         store name

·         store ID

·         store country

·         store address

·         two photos of the retail stores (front and interior of retail stores)

·         MCC

·         any other relevant Secondary Merchant information as reasonably requested by Alipay from time to time

·         business name (registered and ‘trading as’ name)

·         registration number

·         Secondary Merchant type

·         country of incorporation

·         registered address

·         domain name of Secondary Merchants’ website (or the App download URL of online sites) 

·         MCC

·         any other relevant Secondary Merchant information as reasonably requested by Alipay from time to time

ii. Overseas Acquirers must submit full Secondary Merchant information to Alipay via the Payment API as required and ensure that Secondary Merchant information is true, accurate and complete.

2) Secondary Merchant Risk Monitoring

Overseas Acquirers must have adequate risk controls and systems in place to monitor each of its Secondary Merchants to ensure compliance with these Risk Management Requirements including but not limited to the following:

a) Prohibited Products: Overseas Acquirers must procure that its Secondary Merchants do not sell Prohibited Products through Alipay’s platform. The full list of Prohibited Products are annexed to the Alipay Service Contract and will be amended and notified to the Acquirer from time to time.

b) False Trading: Overseas Acquirers are obliged to monitor and supervise the operations of its Secondary Merchants and ensure that all Transactions submitted by Secondary Merchants are authentic transactions and conducted based on authentic trading background.

c) Unauthorized Payment and Fraud Prevention: Overseas Acquirers are obliged to monitor and supervise each of its Secondary Merchants to prevent unauthorized payments and fraud. In the event of unauthorized payments or fraudulent transactions, the Acquirer must cooperate with Alipay to mitigate relevant Transaction risks including but not limited to: i) adjusting payment limits; ii) withholding Payments or settlements; iii) suspending or terminating the provision of Alipay Services (in part or in whole) to its Merchants; and/or iv) indemnifying Alipay for any damages, losses and liabilities it may suffer as a result of Unauthorized Payments or fraudulent Transactions.

d) Product Misuse: Overseas Acquirers are obliged to monitor Secondary Merchants on an ongoing basis for potential product misuse, including but not limited to the following types of misuse:

i. Misuse of Alipay offline products in online scenarios;

ii. Misuse of Alipay online products in offline scenarios;

iii. Misuse of Alipay overseas offline products in Chinese Mainland;

iv. Misuse of Alipay overseas products in any countries or regions where the Acquirer is not authorized to operate; and

v. Transactions conducted by a Secondary Merchant through another Acquirer or a Secondary Merchant not authorized by Alipay.

e) Fund Settlement: Overseas Acquirers must directly settle Transaction amounts to Secondary Merchants and must not settle to any other third-party Overseas Acquirers or independent sales organizations.

f) Mandatory Transaction Information Reporting: Overseas Acquirers must provide, and procure each of its Secondary Merchants provide Mandatory Transaction Information for each Transaction submitted to Alipay as set forth in the Appendix of the Alipay Service Contract (as amended and notified to the Acquirer from time to time). The Acquirer must ensure that all Mandatory Transaction Information submitted in relation to its Secondary Merchant’s Transactions are true, accurate and complete.

3) Secondary Merchant Risk Investigation

Acquirer must, reasonably and in a timely manner, mitigate any risks identified in the process of Secondary Merchants Risk Monitoring or as notified by Alipay.

Overseas Acquirers must cooperate with Alipay in the event of suspicious Secondary Merchants and/or transaction investigations conducted by Alipay. Overseas Acquirers must provide, or procure that its Secondary Merchant provide relevant and necessary information including but not limited to Secondary Merchants’ information, business license, website/ or the App download URL (for online Secondary Merchants), two photos of the offline Secondary Merchant (front and the interior of the retail stores), and transaction evidence (e.g. invoices, receipts, proof of shipping, proof of delivery). Overseas Acquirers may conduct onsite visits when investigating suspicious Secondary as necessary or as per requests of Alipay.

4) Secondary Merchant Risk Non Compliance

If Alipay reasonable suspects that a Merchant is in violation of or in breach of these Risk Management Requirements and any provision of the Alipay Service Contract, Overseas Acquirers should cooperate with Alipay to conduct appropriate remediation actions, including but not limited to:

a) Suspension of Merchant Accounts: Overseas Acquirers shall suspend the accounts of suspicious or non-compliant merchants as necessary or as notified by Alipay.

b) Termination: If a Secondary Merchant violates applicable and critical rules and requirements (as notified by Alipay or as determined in the Overseas Acquirer’s sole discretion), the Overseas Acquirer shall terminate the service provided to the non-compliant merchant.

2. Overseas Acquirers Risk Management

Alipay may be required to conduct additional investigation and risk assessments of the Overseas Acquirers if Alipay determines that it is necessary to take appropriate and reasonable risk measures in the following circumstances:

a) if the average monthly amounts of Acquirer exceeds a threshold determined by Alipay as necessary according to its risk assessments; or

b) if Alipay has concerns about the Acquirer’s operating conditions including concerns raised by negative news, customer feedback and User Complaints.

Overseas Acquirers will be notified of all investigations conducted by Alipay which may take the form of Transaction information requests, enquiries, management interviews and/or on-site visits. Overseas Acquirers must, and procure that its Secondary Merchant cooperate with Alipay to provide relevant information or documents reasonably requested by Alipay.

3. Overseas Acquirers Non Compliance

If Alipay reasonable suspects that a number of Secondary Merchants or the Overseas Acquirer are in violation of, or in breach of these Risk Management Requirements and any provision of the Alipay Service Contract, Alipay may take one or more of the following remediation actions:

i. serving a Notice of Non-Compliance;

ii. issuing a warning notice setting out the consequences for non-compliance;

iii. suspending or restricting new Secondary Merchants onboarding by the Overseas Acquirer;

iv. adjusting Transaction limits;

v. suspending Alipay Services including but not limited to the suspension of Payments for that non-compliant Secondary Merchant(s); and/or

vi. terminating Alipay Services.

In the case of remediation actions against the Secondary Merchant(s), Overseas Acquirer must cooperate with Alipay and carry out such action as notified and requested by Alipay.

Annex I: Lists of Prohibited and Restricted Products

Part A - Prohibited Products


Information that endangers national security and other illegal political information


Information promoting terrorism and extremist groups


Information relating to hate speech and hate crime


Other politically sensitive negative information


Pornographic and/or erotic products, pictures, channels, and publications


Pornographic and/or erotic services (including but not limited to sex chatting and prostitution)






Gambling devices and accessories


Toxic drugs, precursor chemicals and special addictive drugs


Apparatus fit for use to take dangerous drugs


Apparatus fit for use to produce dangerous drugs


Firearms and ammunition, or military equipment


Current army and police uniform (excluding cosplay costumes)


Imitation firearms, firearm parts or equipment could cause bodily harm


Controlled knives and weapons


Poisonous or hazardous chemicals


Explosives and explosive devices


Radioactive materials


Asbestos and products containing asbestos


Ozone depleting materials


Highly toxic pesticides


Online sale of fireworks and firecrackers


Medical toxic drugs, narcotics drugs, psychoactive drugs, radiopharmaceuticals and other controlled pharmaceutical products


Psychedelic drugs, diet pills and health products containing prohibited ingredients


Illegal sale of prescription drugs, unlicensed drugs, substandard drugs and other illegal drugs


Fetal gender determination products or services


Surrogacy services


Online sale of tobacco including cigarettes


Online sale of electronic cigarettes, electronic cigarette liquids


Human organs, body parts and remains


Endangered and protected species and related products


Endangered and protected plants and related products


Pests and hazardous biological products


Banking products and services (including all types of loans)


Life insurance and investment return dividend insurance


Stocks and securities


Mutual Funds


Loan platforms


Other financial products and services including various types of financial intermediation services


Pawnbroker services


Lucky draws (excluding fairly priced products e.g. Pop Mart)


Sale of financial information (e.g. bank accounts, bank cards)


Illegal sale of payment acceptance terminals (excluding licensed acquirers and ISV)


Monetary and financial certificates (e.g. deposit certificate, commercial paper)


Trading or sale of virtual currencies and NFT


Illegal encashment activities


Illegal or unregistered fund-raising activities




Pyramid schemes and multi-level marketing


Foreign exchange services


Investment in precious metals (e.g. gold, silver) and jade (excluding gold and jewels as consumption goods)


Financial trading software and financial data service


Financial Investment Course


Sale of real estate and related services


Crude oil (excluding gas stations)


Sale of ships and aircraft


Espionage equipment and accessories (e.g. wiretapping and hidden camera)


Signal jammer


Malware, hacking services or accessories


Illegal tools for criminal use (e.g. lock picking tools and accessories)


VPN and other illegal proxy services


Mass texting equipment, software and services for illegal use, e.g. fraud (excluding legal marketing purposes)


Forgery of certificates or stamps


Services to facilitate plagiarism and examination fraud


Sale of personal privacy information and other confidential information


Debt collection services


Goods or services used to improperly obtain traffic or popularity, e.g. click farm (excluding legal marketing purposes)


Human trafficking




Rewards of webcast and live streaming services (being activities that release real-time information to the public in the form of video, audio, graphics and words via internet (excluding sale of goods via webcasting on e-commerce platforms))


Smuggled goods


Services or products that infringe on intellectual property rights


Archaeological and state-protected cultural relics and fossils


Investment immigration services


Superstition services (e.g. Feng Shui, fortune-telling or tarot divination services)


Collectibles with high investment value (e.g. antiques, art, calligraphy and painting)


Auctioned goods (e.g. Goods from Sotheby’s or Christie’s)


Other goods or services that violate relevant PRC laws and regulations or adversely affect the reputation of the Ant Group

Part B - Restricted Products


Prepaid cards and top-ups (including gift cards and other stored value cards)


Online Gaming


Cloud Service (including domain name sales)


Property leasing


Motor Vehicles


Non-investment insurance product


Payment platform

The full lists of Prohibited and Restricted Products are annexed to the Alipay Service Contract and will be amended by Alipay and notified to the Acquirer from time to time.

Updated on May 30, 2023