Errors when connecting payments on the Internet
Today we will talk about the most common, in my opinion, errors in connecting payments on the Internet. Incorrectly chosen scheme can result in the disconnection of the outlet from the payment system, its entry into the TMF (Terminated Merchant File) and fines. During the time I work at ChronoPay, I came across a wide variety of ways to connect and bypass the rules of the IPU, so the article was written entirely from my experience :)
Let's start with the simplest and most common, “ we connect physicists ”. According to the law of the Russian Federation, for doing business in the Internet you need the status of an Individual Entrepreneur (IP) or a legal entity (Art. 23 of the Civil Code of the Russian Federation). Without registration, such activity can also be classified as Illegal Entrepreneurship (171 of the Criminal Code of the Russian Federation). The threat is not the most serious, but it can “shoot” at the most inopportune moment.
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Point 2 - the choice of payment methods . If you sell pizza online or women's clothing, you are unlikely to need electronic money. Remember, all your customers already have cards! Electronic money, in my opinion, is needed in some cases for convenience. For example, for instant payment of the lottery winnings on Qiwi, or hosting payment. If you are selling fashionable women's clothing or hot pizza on the Internet - hardly anyone will pay for such goods via WebMoney.
Point 3 is the right bank card connection scheme . So, let's focus on the maps. You have chosen a certain payment gateway, let's call it abstractly SuperPay. I call the correct scheme one in which you have concluded two agreements: one agreement with an acquiring bank, the second agreement with a payment gateway. In this case, under the first contract, the acquiring bank transfers money to you and immediately withholds its commission; for the second, you pay for the gateway services, for example, once a month. Why, in my opinion, is it correct? Because the Bank pays you directly - for liquidity (solvency) which is monitored by the Bank of Russia (CB). In other words, the more reliable the bank is, the more your money is protected. If you pay another jur. a person (and there are such schemes and work according to the Civil Code) —that there is no need to speak about any control by the Central Bank. Here you either trust or not - but the risk is much greater.
Point 4 - facilitation scheme . A facilitator is an organization that, on behalf of the acquiring bank, concludes contracts with customers and conducts settlements with them. Facilitators were invented for good purposes - to remove the huge paperwork and calculations from banks for small clients. The bank forwards the entire turnover to such clients to the facilitator, and he conducts calculations. At the same time, the site facilitator checks, contracts are signed by the facilitator, as well as the facilitator bears all risks for its clients (i.e., the IPU finishes the acquiring bank, the bank finishes the facilitator, and the latter, if it has time, writes money off the client). At the same time, MPS requires the acquirer to register each outlet separately, i.e. if everything works correctly, the facilitator sends an application for registration of the “cash register” (MID) to the acquirer through which all payments will go. Determining whether you are registered correctly is simple enough - by bank statement (after purchase), and it must contain a type descriptor “superpay-magazin”, where superpay is the name of the facilitator, magazine is the name of your store. The risks, in my opinion, are obvious here - another link through which the money passes.
Point 5 - abuse of electronic wallets . IPS Visa / MasterCard include in their requirements two rules:
1) each outlet must be registered separately;
2) the acquiring bank can connect legal entities and individual entrepreneurs only in the jurisdiction where it is located, if it does not have a special cross-board license.
No one in Russia has such a license. in fact, a Russian bank can only connect a Russian legal entity (or individual).
There is also a rather popular scheme of deception of Visa / MasterCard Payment Systems, when for one action (debiting funds from a card) there is a kind of “replenishment of a temporary wallet”, and then money is transferred from that wallet to the seller’s wallet (some NGOs have a sin ). From the point of view of the law (the Law on Banks and Banking) this can be called “transfer of funds on behalf of an individual”. But if you delve into the details, it turns out that the money goes to NPOs through their correspondent accounts in the acquiring banks. And the problem is that such a scheme already violates the rules of the IPU.
It is quite simple to determine: if you see in the bank statement not “superpay-magazin”, but simply “superpay”, and at the same time when you replenish your personal wallet in the same system, the same text appears on the statement. Although this is often seen in the agreement with the payment gateway - whether he undertakes to register a separate outlet in the Ministry of Railways or not.
What can this turn into? Penalty and disabling - especially if you come to the attention of competitors who can "contribute". MasterCard, for example, calls such an aggregation of transactions from different merchants - “Transaction Laundering”, and strictly prohibits such activity.
For a payment gateway, such a method is an increase in turnover at their own point (purchase of virtual currency), the logic here is very simple - the greater the turnover, the lower the rate of accepting payments from the acquiring bank, the greater the profit of such a gateway. For you, this is a significant risk. Without having a direct contract with a bank, you will long argue in court that you did not violate anything, the penalty is not yours, and the money was not illegally paid to you.
Even worse, when non-residents are connected to such schemes, two whole rules of the IPM mentioned above are already violated. By the way, the largest violator of the rules of the Ministry of Railways (on both counts), according to the author, is the favorite Ali Express store in Russia. But it seems that the “everyone’s equal” rule once established by Di Hawk doesn’t work here. It happens to those who are more equal. Remember where you are and where Alien’s billionth turn is. If you take a smaller company, in my opinion, a similar example can be CIAN (see bank statement).
Another abuse of the rules is the connection of gambling sites (betting, casino) through such a scheme. If you have such a site, you need to know that, from the point of view of Visa, for example, Gambling is classified as High-Brand Risk and requires not only direct registration of the outlet, but also Visa’s written permission to accept such payments. Gambling, Adult, Pharmacy are described in a separate program, the Visa Global Brand Protection Program. Despite the fact that penalties for incorrect registration are already calculated at $ 25,000 per month of operation of such an outlet. You have worked for half a year, Visa caught you - you will already pay $ 150,000 fine. A similar program in MasterCard is Business Risk Assessment and Mitigation (BRAM). In general, you also get a penalty from MasterCard. Nevertheless, we also have such NGOs who connect high-risk clients through the replenishment of their wallets.
Point 6 - the choice of bank-acquirer . What should I pay attention to in my opinion is the value of the rate and on which day the bank pays reimbursement for transactions. Each transaction has a cost price - which consists of an interchange (returned to the bank that issued the card) and the IPU commission. Details about the formation of rates, I wrote in the article: the cost of acquiring . In this case, the banks are also sitting experts and maintenance of the Internet stream is also worth something. If the bank gives a bet on the verge of cost (1.7%) - then you should think about it, but is everything good in this bank? The second point is if the bank pays on the third day or later. MPS is calculated with acquirers on the third day. Even one day is enough for a bank to turn your money, for example, in the interbank lending market.
Let's start with the simplest and most common, “ we connect physicists ”. According to the law of the Russian Federation, for doing business in the Internet you need the status of an Individual Entrepreneur (IP) or a legal entity (Art. 23 of the Civil Code of the Russian Federation). Without registration, such activity can also be classified as Illegal Entrepreneurship (171 of the Criminal Code of the Russian Federation). The threat is not the most serious, but it can “shoot” at the most inopportune moment.
')
Point 2 - the choice of payment methods . If you sell pizza online or women's clothing, you are unlikely to need electronic money. Remember, all your customers already have cards! Electronic money, in my opinion, is needed in some cases for convenience. For example, for instant payment of the lottery winnings on Qiwi, or hosting payment. If you are selling fashionable women's clothing or hot pizza on the Internet - hardly anyone will pay for such goods via WebMoney.
Point 3 is the right bank card connection scheme . So, let's focus on the maps. You have chosen a certain payment gateway, let's call it abstractly SuperPay. I call the correct scheme one in which you have concluded two agreements: one agreement with an acquiring bank, the second agreement with a payment gateway. In this case, under the first contract, the acquiring bank transfers money to you and immediately withholds its commission; for the second, you pay for the gateway services, for example, once a month. Why, in my opinion, is it correct? Because the Bank pays you directly - for liquidity (solvency) which is monitored by the Bank of Russia (CB). In other words, the more reliable the bank is, the more your money is protected. If you pay another jur. a person (and there are such schemes and work according to the Civil Code) —that there is no need to speak about any control by the Central Bank. Here you either trust or not - but the risk is much greater.
Point 4 - facilitation scheme . A facilitator is an organization that, on behalf of the acquiring bank, concludes contracts with customers and conducts settlements with them. Facilitators were invented for good purposes - to remove the huge paperwork and calculations from banks for small clients. The bank forwards the entire turnover to such clients to the facilitator, and he conducts calculations. At the same time, the site facilitator checks, contracts are signed by the facilitator, as well as the facilitator bears all risks for its clients (i.e., the IPU finishes the acquiring bank, the bank finishes the facilitator, and the latter, if it has time, writes money off the client). At the same time, MPS requires the acquirer to register each outlet separately, i.e. if everything works correctly, the facilitator sends an application for registration of the “cash register” (MID) to the acquirer through which all payments will go. Determining whether you are registered correctly is simple enough - by bank statement (after purchase), and it must contain a type descriptor “superpay-magazin”, where superpay is the name of the facilitator, magazine is the name of your store. The risks, in my opinion, are obvious here - another link through which the money passes.
Point 5 - abuse of electronic wallets . IPS Visa / MasterCard include in their requirements two rules:
1) each outlet must be registered separately;
2) the acquiring bank can connect legal entities and individual entrepreneurs only in the jurisdiction where it is located, if it does not have a special cross-board license.
No one in Russia has such a license. in fact, a Russian bank can only connect a Russian legal entity (or individual).
There is also a rather popular scheme of deception of Visa / MasterCard Payment Systems, when for one action (debiting funds from a card) there is a kind of “replenishment of a temporary wallet”, and then money is transferred from that wallet to the seller’s wallet (some NGOs have a sin ). From the point of view of the law (the Law on Banks and Banking) this can be called “transfer of funds on behalf of an individual”. But if you delve into the details, it turns out that the money goes to NPOs through their correspondent accounts in the acquiring banks. And the problem is that such a scheme already violates the rules of the IPU.
It is quite simple to determine: if you see in the bank statement not “superpay-magazin”, but simply “superpay”, and at the same time when you replenish your personal wallet in the same system, the same text appears on the statement. Although this is often seen in the agreement with the payment gateway - whether he undertakes to register a separate outlet in the Ministry of Railways or not.
What can this turn into? Penalty and disabling - especially if you come to the attention of competitors who can "contribute". MasterCard, for example, calls such an aggregation of transactions from different merchants - “Transaction Laundering”, and strictly prohibits such activity.
For a payment gateway, such a method is an increase in turnover at their own point (purchase of virtual currency), the logic here is very simple - the greater the turnover, the lower the rate of accepting payments from the acquiring bank, the greater the profit of such a gateway. For you, this is a significant risk. Without having a direct contract with a bank, you will long argue in court that you did not violate anything, the penalty is not yours, and the money was not illegally paid to you.
Even worse, when non-residents are connected to such schemes, two whole rules of the IPM mentioned above are already violated. By the way, the largest violator of the rules of the Ministry of Railways (on both counts), according to the author, is the favorite Ali Express store in Russia. But it seems that the “everyone’s equal” rule once established by Di Hawk doesn’t work here. It happens to those who are more equal. Remember where you are and where Alien’s billionth turn is. If you take a smaller company, in my opinion, a similar example can be CIAN (see bank statement).
Another abuse of the rules is the connection of gambling sites (betting, casino) through such a scheme. If you have such a site, you need to know that, from the point of view of Visa, for example, Gambling is classified as High-Brand Risk and requires not only direct registration of the outlet, but also Visa’s written permission to accept such payments. Gambling, Adult, Pharmacy are described in a separate program, the Visa Global Brand Protection Program. Despite the fact that penalties for incorrect registration are already calculated at $ 25,000 per month of operation of such an outlet. You have worked for half a year, Visa caught you - you will already pay $ 150,000 fine. A similar program in MasterCard is Business Risk Assessment and Mitigation (BRAM). In general, you also get a penalty from MasterCard. Nevertheless, we also have such NGOs who connect high-risk clients through the replenishment of their wallets.
Point 6 - the choice of bank-acquirer . What should I pay attention to in my opinion is the value of the rate and on which day the bank pays reimbursement for transactions. Each transaction has a cost price - which consists of an interchange (returned to the bank that issued the card) and the IPU commission. Details about the formation of rates, I wrote in the article: the cost of acquiring . In this case, the banks are also sitting experts and maintenance of the Internet stream is also worth something. If the bank gives a bet on the verge of cost (1.7%) - then you should think about it, but is everything good in this bank? The second point is if the bank pays on the third day or later. MPS is calculated with acquirers on the third day. Even one day is enough for a bank to turn your money, for example, in the interbank lending market.
Source: https://habr.com/ru/post/283484/
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