High Risk Merchant Handbook

Getting a Gambling Merchant Account

A gambling merchant account needs more than a bank's yes. Visa and Mastercard both set rules the acquirer must meet.

A gambling merchant account is a card processing account for a business that takes bets. It is not just a bank decision. Visa and Mastercard both impose their own rules, and your acquirer must satisfy them before your first charge. You supply some of the paperwork.

Why gambling is a special case

Card networks treat gambling differently from a shoe store. Visa and Mastercard each set extra rules for it.

To learn more, read why banks watch payment processors.

Mastercard registration

Mastercard makes some gambling merchants register. The rule covers MCCs 7801, 7802 and 7995, when the sale is not face to face. Non-face-to-face means the customer is not there in person, as with online bets.

Mastercard's manual says the acquirer must register the merchant with Mastercard first. Only then may it process these bets. Mastercard's manual names two forms.

Mastercard's manual says the Customer must send in the Acquirer Intake Form. It covers non-face-to-face gambling, lottery and skill games. Mastercard's manual also asks for a Merchant Attestation. Non-face-to-face gambling and skill games merchants must fill it out and send it.

Registration is only part of the file. Mastercard's rules say the acquirer must get and keep a copy of each gambling license. Each copy must come from the government office that issued it. Expect to hand over every license you hold, not just one.

The acquirer also needs a legal opinion. Mastercard's rules say the legal opinion must list every law that applies to the merchant. That includes state lottery laws.

Merchant Category Codes for gambling

Visa's rules list MCC 7801 for government licensed on-line casinos. They list MCC 7995 for betting, including lottery tickets, casino gaming chips, off-track betting and wagers at race tracks.

Visa's manual says a merchant conducting online gambling transactions must use MCC 7995 for all transactions, even if gambling is not the primary business. The same rule applies in person. Visa's manual says a merchant conducting gambling transactions in a card-present environment must use MCC 7995 for those transactions.

Visa's rules also treat online bets like cash. They must be processed as quasi-cash transactions.

When gambling is only part of the business

Mixed merchants trip up here. If you run a store with a betting counter, the bets still carry MCC 7995 under Visa's rule. Online, Visa's manual says every sale uses MCC 7995.

Wallets follow the same logic. Visa's manual says a transaction on behalf of another high-risk merchant must use that merchant's MCC, such as 7995 for loading a gambling wallet. Visa's guide also covers digital wallets. A wallet used for illegal gambling falls under this category too.

Visa's rules include a table of website requirements for online gambling merchants, marketplaces or merchants that undertake transactions for the acquisition of non-fiat currency. If you run an online gambling site, ask your acquirer what that table asks of you.

Ongoing duties after approval

Approval is not the end of the work. Mastercard's rules say a gambling merchant must give its acquirer monthly reports listing flagged content and complaints received. Set a calendar reminder now.

Mastercard's rules also cover fights with customers. A neutral body must settle them, and the merchant pays the cost. Two more rules cover your site itself. A gambling merchant must not attract users to its website with adult content that is illegal or violates the Standards. It must have policies that bar its website from promoting human trafficking, sex trafficking or physical abuse.

Visa adds rules for how charges appear. Visa's manual says acquirers must prohibit agents from using dynamic merchant descriptors for gambling merchants. So agents may not use a descriptor that changes.

Visa's rules also say an issuer of a Visa Commercial Card may choose to block gambling transactions. Some corporate cardholders cannot bet with their cards no matter what you do.

Skill games and fantasy sports

Skill games sit in a different category. Visa's manual says MCC 5816 covers games of skill, excluding games of chance, delivered in electronic format, including in-app purchases. That code is for games of skill, not games of chance.

Mastercard has a rule for a nearby case. Mastercard's manual says a merchant whose non-face-to-face high-risk trading is regulated as gambling must be registered as a non-face-to-face gambling merchant. Ask a lawyer whether your product counts as gambling where you sell.

Misclassification and transaction laundering

The codes must be right. Visa's guide says acquirers and agents must ensure gambling transactions use the correct Merchant Category Codes and Point-of-Sale Condition Codes. Visa's guide also warns about wrong codes. An entity that miscodes a gambling merchant breaks the Visa Rules. Visa may then act against it.

Visa's guide says crooked businesses use transaction laundering. They use it for illegal gambling, fake pharmacies, illegal drugs and counterfeit goods. Transaction laundering means running one merchant's charges through another merchant's account. Never let a partner process bets through your account, and never route your bets through someone else's.

Before you apply

Talk to a lawyer before you apply. The legal opinion alone requires one. Whether your product counts as gambling is a legal question too. Ask the lawyer, then ask the processor what file it wants.

Visa puts some business types in its top risk tier for card-absent sales. That tier includes gambling, adult content, dating and escort services, and pharmacies. If you also sell by phone, read up on billing authorization on phone sales.

Build the file first, then apply.

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