Recent Mastercard Updates to the BRAM Program – AN 4175
Mastercard announced new additions to the Business Risk Assessment and Mitigation (BRAM) program – targeting further illegal or brand-damaging activities, and updates to recent regulatory actions regarding online gambling transactions in Portugal, Germany, United Kingdom and Lithuania.
Additions to BRAM Program
1. COVID-19 Related Marketing and Sales
The recent COVID-19 pandemic has led a surge in the distribution of fraudulent COVID-19 home test kits, cures and vaccines – resulting in the sale of any goods or services either through an affiliate marketer or directly from the merchant of record, that intends to test, cure, treat or prevent COVID-19, to be considered a BRAM violation if unapproved by relevant government or regulatory authorities
2. Celebrity Endorsements
Any unauthorised use of a celebrity’s name, image or other aspect of their identity in marketing and/or sale of a good or service either through an affiliate marketer or directly from the merchant of record, will be considered a BRAM violation. Acquirer must be able to provide Mastercard with sufficient documentation to support the use of the celebrity’s identity within the timeframe requested.
3. Electronic Nicotine Delivery Systems (ENDS)
Due to recent legislation in the US that restricts the sale of electronic nicotine delivery systems (ENDS), such as e-cigarettes, vape pens, and cartridge refills, acquirers must register any tobacco product merchant that conducts non-face-to-face (NFTF) transactions via the Mastercard Registration Program (MRP). Mastercard enforces all acquirers to identify merchants or submerchants whose primary business is the sale of ENDS, to allocate card acceptor business code (MCC) 5993 and transaction category code (TCC) T for non-face-to-face transactions or TCC R for face-to-face transactions.
Regulatory Information Regarding Internet Gambling
The following regulatory information on Internet gambling transactions, is in regards to Portugal, Germany, United Kingdom and Lithuania. Gambling merchants operating within Germany, Portugal or Lithuania must be appropriately licensed by authorities in their country. For any Internet gambling activities processed through the Mastercard network in jurisdictions where it is illegal, is deemed a BRAM violation.
Under new licensing requirement in the United Kingdom, the use of credits are banned for all forms of remote gambling (e.g. betting, gaming, lotteries) and for non-remote betting. Therefore, a merchant with any of the following types of operating licenses are unable to accept payment by credit card.
Remote Operating Licenses
- Casino
- Bingo
- General Betting (real events)
- General Betting (virtual events)
- General Betting (limited)
- Pool Betting
- Betting Intermediary
- External Lottery Manager
- Society Lottery
Non-Remote Operating Licenses
- General Betting (limited)
- General Betting (standard)
- Pool Betting
- Betting Intermediary
Source: AN 4175 Updates for the Business Risk Assessment and Mitigation Program 30 June 2020