Risk Management Requirements for Alipay Overseas Acquirers


The management requirements apply to Alipay overseas cooperative acquirers.


1.       Acquirers’ Obligations on Secondary Merchants Risk Management

1.1    Secondary Merchant Onboarding

a)    Merchant Requirements:

I.    Overseas Acquirers shall not onboard any merchants who sell prohibited products, including but not limited to any products related to pornography, gambling, illegal drugs, weapons, financial business and illegal political contents (for the full list of prohibited product, please refer to the Alipay Prohibited Product List attached hereunder as Annex I).

II.    Overseas Acquirers shall only onboard merchants with bona fide business purposes (the merchants shall not engage in any fraud or false trading, transaction laundering, disposal of stolen goods or any other illegal activities).

b)    Offline Merchant Pre-onboarding: in respect of any offline merchants onboarding, Overseas Acquirers shall provide the name and ID of the secondary merchants, the store name, Store ID, address and two photos of the retail stores (one for the front and the other for the interior of the retail stores) and MCC. Also, Overseas Acquirers shall submit the full information of merchants’ transactions (including the name and ID of secondary merchants, the store name, Store ID of the retail stores and MCC) to Alipay via the payment API as required, and the information so submitted shall be consistent with the pre-onboarding merchants’ information.

c)    Online Merchant Pre-onboarding: in respect of any online merchant onboarding, Overseas Acquirers shall provide the name and ID of the secondary merchants, the domain name of merchants’ website or the App download URL and website or App MCC. In addition, Overseas Acquirers shall also provide full information of merchants’ transactions (including the name and ID of the secondary merchant, the domain name of merchants’ website or App download URL and website or App MCC) to Alipay via the payment API as required, and the information so submitted shall be consistent with the pre-onboarding merchant information.


1.2    Secondary Merchants Risk Monitoring

a)    Prohibited Products: Overseas Acquirers are obliged to prevent secondary merchants from trading any prohibited products, including but not limited to any products related to pornography, gambling, illegal drugs, weapons, financial business and illegal political contents (for the full list of prohibited product, please refer to the Alipay Prohibited Product List attached hereunder as Annex I).

b)    False Trading: Overseas Acquirers are obliged to supervise any operations of secondary merchants and shall ensure that all transactions of merchants are conducted based on authentic trading background.

c)    Merchant Fraud: Overseas Acquirers are obliged to supervise secondary merchants to prevent merchant fraud. In the event that any unauthorized transactions, merchant fraud or any other violation of applicable rules notified to Alipay, the Overseas Acquirer shall cooperate with Alipay to mitigate relevant transaction risks by the following means (including but not limited to): withholding any payments or settlements, suspending/terminating cooperation with secondary merchants and making any indemnification.

d)    Transaction Laundering: Overseas Acquirers are obliged to monitor secondary merchants on transaction laundering, including but not limited to

  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 Mainland China scenarios;

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

  V.    Laundering transactions conducted by a secondary merchant through another merchant or another secondary merchant.

e)    Fund Settlement: Overseas Acquirers shall directly settle transaction amounts to secondary merchants (as opposed to settling transaction amounts to any other third-party acquirers or independent sales organizations, which in turn settle the amounts to merchants).


1.3    Secondary Merchant Non-compliance

Overseas Acquirer shall timely mitigate any risks identified in the process of merchants risk monitoring or as notified by Alipay and shall cooperate with Alipay to mitigate the relevant risks so identified.

a)    Merchant Investigation: Overseas Acquirer shall cooperate with Alipay in suspicious merchants investigations by way of procuring relevant transaction information, including but not limited to merchants’ information, business license, transaction evidence (e.g. invoices, receipts, proof of shipping, proof of delivery). Overseas Acquirer shall conduct the onsite visit to suspicious merchants as necessary or as per requests of Alipay.

b)    Suspending Merchant Accounts: acquirers shall suspend the accounts of suspicious or non-compliant merchants as necessary or as notified by Alipay.

c)    Termination: if a secondary merchant violates applicable and critical rules (as notified by Alipay or to the Overseas Acquirer’s sole discretion), the Overseas Acquirer shall terminate the service provided to the non-compliant merchant.


2.    Overseas Acquirers Risk Management

Overseas Acquirer may be subject to additional investigation and risk assessment under the following circumstances:

a)    Average amounts of acquiring in each month exceeding a threshold decided by Alipay;

b)    Any concerns about the Overseas Acquirer’s operating conditions raised by negative news, customer complaints or other indications

Overseas Acquirer will be notified by Alipay of the investigation in forms of inquiries, management interview or on-site review and are obliged to cooperate with Alipay in such investigations and deliver relevant documents as reasonably required.


Updated on August 27, 2018


Annex I: Alipay Prohibited Products List



1

Illegal political products and publications

2

Illegal political program channels

3

State secret documents and information

4

Pornographic and vulgar audio visual products, channels, and publications

5

Pornographic and vulgar erotic services

6

Gambling

7

Gambling devices and accessories

8

Lottery

9

Narcotics and related accessories

10

Weapons of all types (including daggers, firearms and accessories, replica weapons, ammunitions and explosives)

11

Military or police equipment

12

Illegally obtained proceeds or properties as result of a crime

13

Poisonous or hazardous chemicals

14

Batons and electric batons

15

Lockpicking tools and accessories

16

Anesthetic, psychotropic or prescription medicine; illegal unregistered medicine

17

Fetal gender determination

18

Aphrodisiac

19

Online sale of medical services, including medical consulting, hypnotherapy, plastic surgery

20

Hacking services or accessories

21

Malwares

22

Illegal publication of certificates or carving of stamps

23

Crowd funding

24

Video chatting services

25

All religious websites, publication or accessories

26

Online cemeteries and ancestor worshipping

27

Sales of personal information (e.g. identity card information)

28

Espionage equipment and accessories

29

Services or products that infringe on personal privacy (e.g. online activity monitoring)

30

Pyramid schemes and multi-level marketing

31

Gold investment

32

Cashback from Alipay account

33

Counterfeit currency

34

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

35

Stock and securities

36

Mutual Funds

37

Insurance products and platforms

38

Financial products and services

39

Rebate or cashback services

40

Software or products related to trading of financial products and information

41

Single-purpose prepaid cards (including gift cards and other stored value cards)

42

Illegal or unregistered fund-raising activities

43

Foreign exchange services

44

Peer to peer (P2P) lending services

45

Payment by instalments service

46

Trading in invoices issued within the Peoples’ Republic of China

47

Trading or sale of virtual currencies (e.g. Bitcoin, Litecoin)

48

Satellites antennas

49

Archaeological and cultural relics

50

Trading or distribution of currency (both RMB and foreign currencies)

51

Counterfeit or replica food products

52

Online sale of tobaccos and cigarettes

53

Fireworks and firecrackers

54

Crude oil

55

Human organs

56

Surrogacy services

57

Services to facilitate plagiarism and examination fraud

58

Protected species

59

Smuggled goods

60

Sales of distribution of event tickets without the license (e.g. Olympic Games or World Expo tickets)

61

Seeds

62

Real estate

63

Charitable Organizations

64

Auction sites and services

65

Pawn services

66

Lucky draws

67

Sale of animals, plants or products with contagious and hazardous diseases

68

Sale of animals, plants or products originating from areas declared with an epidemic outbreak of contagious diseases

69

Services or products facilitating the unlawful public gathering


As updated by Alipay from time to time.


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