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    Risk Management Requirements for Overseas Acquirers

    These Risk Management Requirements apply to all Alipay overseas cooperative acquirers (“Overseas Acquirers”) having entered into an Alipay Service Contract with Alipay.com Co. Ltd (“Alipay”). This document sets out the Acquirer’s key responsibilities for managing risks associated with providing payment processing, authorization and settlement services to its Secondary Merchants and enabling its Secondary Merchants to accept Alipay Services indirectly through it.


    All Overseas Acquirers must ensure that their business operations and its Secondary Merchants comply with these Risk Management Requirements.


    Unless otherwise defined herein, capitalized terms used in this document have the meanings given to them in the Alipay Service Contract between the Overseas Acquirer and Alipay.

    #1. Overseas Acquirer’s Key Responsibilities

    1) Secondary Merchant Onboarding

    Overseas Acquirers must conduct Due Diligence on all prospective Secondary Merchants prior to onboarding including but not limited to the following:

    a) Secondary Merchant Requirements

    i. Overseas Acquirers must not onboard any Merchants who sell Prohibited Products specified in Annex I.

    ii. Overseas Acquirers must only onboard Merchants with bona fide business purposes.

    b) Secondary Merchant Information

    i. Overseas Acquirers must provide or procure that the relevant Secondary Merchant provide complete and accurate information in relation to that Merchant as requested by Alipay including but not limited to:

    Offline Secondary Merchants

    Online Secondary Merchants

    ·         business name (registered and ‘trading as’ name)

    ·         registration number

    ·         Secondary Merchant type

    ·         country of incorporation

    ·         registered address

    ·         store name

    ·         store ID

    ·         store country

    ·         store address

    ·         two photos of the retail stores (front and interior of retail stores)

    ·         MCC

    ·         any other relevant Secondary Merchant information as reasonably requested by Alipay from time to time

    ·         business name (registered and ‘trading as’ name)

    ·         registration number

    ·         Secondary Merchant type

    ·         country of incorporation

    ·         registered address

    ·         domain name of Secondary Merchants’ website (or the App download URL of online sites) 

    ·         MCC

    ·         any other relevant Secondary Merchant information as reasonably requested by Alipay from time to time

    ii. Overseas Acquirers must submit full Secondary Merchant information to Alipay via the Payment API as required and ensure that Secondary Merchant information is true, accurate and complete.


    2) Secondary Merchant Risk Monitoring

    Overseas Acquirers must have adequate risk controls and systems in place to monitor each of its Secondary Merchants to ensure compliance with these Risk Management Requirements including but not limited to the following:

    a) Prohibited Products: Overseas Acquirers must procure that its Secondary Merchants do not sell Prohibited Products through Alipay’s platform. The full list of Prohibited Products are annexed to the Alipay Service Contract and will be amended and notified to the Acquirer from time to time.

    b) False Trading: Overseas Acquirers are obliged to monitor and supervise the operations of its Secondary Merchants and ensure that all Transactions submitted by Secondary Merchants are authentic transactions and conducted based on authentic trading background.

    c) Unauthorized Payment and Fraud Prevention: Overseas Acquirers are obliged to monitor and supervise each of its Secondary Merchants to prevent unauthorized payments and fraud. In the event of unauthorized payments or fraudulent transactions, the Acquirer must cooperate with Alipay to mitigate relevant Transaction risks including but not limited to: i) adjusting payment limits; ii) withholding Payments or settlements; iii) suspending or terminating the provision of Alipay Services (in part or in whole) to its Merchants; and/or iv) indemnifying Alipay for any damages, losses and liabilities it may suffer as a result of Unauthorized Payments or fraudulent Transactions.

    d) Product Misuse: Overseas Acquirers are obliged to monitor Secondary Merchants on an ongoing basis for potential product misuse, including but not limited to the following types of misuse:

    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 Chinese Mainland;

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

    v. Transactions conducted by a Secondary Merchant through another Acquirer or a Secondary Merchant not authorized by Alipay.

    e) Fund Settlement: Overseas Acquirers must directly settle Transaction amounts to Secondary Merchants and must not settle to any other third-party Overseas Acquirers or independent sales organizations.

    f) Mandatory Transaction Information Reporting: Overseas Acquirers must provide, and procure each of its Secondary Merchants provide Mandatory Transaction Information for each Transaction submitted to Alipay as set forth in the Appendix of the Alipay Service Contract (as amended and notified to the Acquirer from time to time). The Acquirer must ensure that all Mandatory Transaction Information submitted in relation to its Secondary Merchant’s Transactions are true, accurate and complete.


    3) Secondary Merchant Risk Investigation

    Acquirer must, reasonably and in a timely manner, mitigate any risks identified in the process of Secondary Merchants Risk Monitoring or as notified by Alipay.

    Overseas Acquirers must cooperate with Alipay in the event of suspicious Secondary Merchants and/or transaction investigations conducted by Alipay. Overseas Acquirers must provide, or procure that its Secondary Merchant provide relevant and necessary information including but not limited to Secondary Merchants’ information, business license, website/ or the App download URL (for online Secondary Merchants), two photos of the offline Secondary Merchant (front and the interior of the retail stores), and transaction evidence (e.g. invoices, receipts, proof of shipping, proof of delivery). Overseas Acquirers may conduct onsite visits when investigating suspicious Secondary as necessary or as per requests of Alipay.


    4) Secondary Merchant Risk Non Compliance

    If Alipay reasonable suspects that a Merchant is in violation of or in breach of these Risk Management Requirements and any provision of the Alipay Service Contract, Overseas Acquirers should cooperate with Alipay to conduct appropriate remediation actions, including but not limited to:

    a) Suspension of Merchant Accounts: Overseas Acquirers shall suspend the accounts of suspicious or non-compliant merchants as necessary or as notified by Alipay.

    b) Termination: If a Secondary Merchant violates applicable and critical rules and requirements (as notified by Alipay or as determined in the Overseas Acquirer’s sole discretion), the Overseas Acquirer shall terminate the service provided to the non-compliant merchant.

    #2. Overseas Acquirers Risk Management

    Alipay may be required to conduct additional investigation and risk assessments of the Overseas Acquirers if Alipay determines that it is necessary to take appropriate and reasonable risk measures in the following circumstances:

    a) if the average monthly amounts of Acquirer exceeds a threshold determined by Alipay as necessary according to its risk assessments; or

    b) if Alipay has concerns about the Acquirer’s operating conditions including concerns raised by negative news, customer feedback and User Complaints.

    Overseas Acquirers will be notified of all investigations conducted by Alipay which may take the form of Transaction information requests, enquiries, management interviews and/or on-site visits. Overseas Acquirers must, and procure that its Secondary Merchant cooperate with Alipay to provide relevant information or documents reasonably requested by Alipay.

    #3. Overseas Acquirers Non Compliance

    If Alipay reasonable suspects that a number of Secondary Merchants or the Overseas Acquirer are in violation of, or in breach of these Risk Management Requirements and any provision of the Alipay Service Contract, Alipay may take one or more of the following remediation actions:

    i. serving a Notice of Non-Compliance;

    ii. issuing a warning notice setting out the consequences for non-compliance;

    iii. suspending or restricting new Secondary Merchants onboarding by the Overseas Acquirer;

    iv. adjusting Transaction limits;

    v. suspending Alipay Services including but not limited to the suspension of Payments for that non-compliant Secondary Merchant(s); and/or

    vi. terminating Alipay Services.

    In the case of remediation actions against the Secondary Merchant(s), Overseas Acquirer must cooperate with Alipay and carry out such action as notified and requested by Alipay.

    #Annex I: Alipay Prohibited Products List

    No

    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

    Updated on April 30, 2019