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Education

Visa's Integrity MCC 4816; games of skill (card absent) – MCC 5816;
pharmacies – MCC 5122, 5912
Risk Program • Tier 3: High integrity risk financial trading plat-
forms (card absent) – MCC 6211; outbound telemar-
keting (card absent) – MCC 5966; subscription "neg-
ative option" merchants (card absent) – MCC 5968;
tobacco sales (cross-border card absent) – MCC 5993
Fee schedule and registration:

Visa will update initial application fees in line with the
new risk tiers and introduce an annual renewal fee for
HIR acquiring. Acquirers must be granted an HIR acquir-
ing registration before boarding HIR merchants. Each tier
category has successively greater requirements such that
if an acquirer is approved for Tier 2, it may board mer-
chants in Tier 2 and Tier 3.

Tier 1 has the most stringent vetting; each of its four mer-
chant types requires independent approval from Visa be-
fore an acquirer may process for that MCC. An acquirer
By Ken Musante approved for Tier 1, for example, may board merchants in
Napa Payments and Consulting Tier 2 and Tier 3, but they may only board Tier 1 MCCs for
the specific MCC they were approved to board.
n April, Visa introduced the Visa Integrity Risk
Program (VIRP) to keep merchants operating ille- To be approved for Tier 1 or Tier 2 categories, the acquirer
gally out of the system. VIRP replaces the Global must undergo a control assessment to validate the acquir-
I Brand Protection Program and requires acquirers to er has the ability to and will properly monitor HIR mer-
institute controls and oversight and prescribes a fee sched- chants. Acquirers with existing merchants in the respec-
ule should the controls not be properly enforced. tive Tiers may continue processing for their clients, but
they will need to apply and pass the annual assessments
These new requirements are daunting and will eliminate on going forward.
some acquirers from supporting individual merchants
within these categories. These displaced merchants will Registration and annual fees
continue to process, however, and will be attracted to The fees for supporting HIR merchants are significant. The
stable acquirers building the support and infrastructure
necessary to board and serve this unique merchant type. initial and annual registration fee is $950 per merchant.
The fee to the acquirer for supporting HIR merchants is
High-integrity risk even greater making it impractical to process for only a
very small number of merchants within an HIR tier.
Visa designates merchants as High-Integrity Risk (HIR)
merchants when they operate in business types that are For Tiers 1 and 2, initial registration and annual renewal
legal, but are in a category where illicit transactions have fee is $100,000 each; for Tier 3, initial registration and an-
been known to flourish. HIR merchants are classified by nual renewal are $25,000 each.
business type and risk level.

HIR merchants require more stringent underwriting stan-
dards and due diligence as well as enhanced monitoring
to mitigate risk. They are classified by tier in accordance Tier 1 has the most
with their perceived risk.
stringent vetting; each of
• Tier 1 – Card not present: adult content – MCC 5967; its four merchant types
dating and escort services – MCC 7273; gambling –
MCC 7995; pharmacies – MCC 5122, 5912 requires independent
• Tier 2: Crypto merchants, including exchanges, approval from Visa before
wallet providers or on-ramp providers (card absent)
– MCC 6051, 6012, with transactions required to use an acquirer may process for
special condition code; cyberlockers and similar that MCC.
remote digital file-sharing services (card absent) –

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