Mastercard's Scam Merchant Monitoring Program (SMMP) has introduced a new, investigation-led framework that works very differently from the ratio-based chargeback programs the industry has relied on for years. It applies to card-not-present merchants globally, and Mastercard's guidance on business models warranting closer attention includes adult content and dating platforms, along with subscription services, digital goods and forex.
For merchants in these verticals, understanding what can trigger an investigation, how their accounts are structured and what their acquiring partners know about their business is becoming increasingly important.
SMMP isn't targeted at any one industry by design, but Mastercard's guidance specifically identifies adult content and dating platforms for closer attention. Discretion needs and billing descriptor confusion are common in these verticals, and both can contribute to the refund and dispute activity SMMP is designed to detect.
What Changed
Mastercard’s older chargeback-ratio programs gave merchants time. Ratios climbed gradually, leaving room to course correct. SMMP works differently. It is signal-based rather than ratio-based. When a qualifying signal appears, the acquirer has 72 hours to investigate. If scam activity is confirmed, Mastercard and Maestro can terminate acceptance immediately.
One trigger in particular that is getting attention combines refunds and chargebacks into a single threshold. During a merchant's first six months of Mastercard acceptance, accounts processing at least 500 transactions in a rolling 30-day period can face investigation if refunds and chargebacks together exceed 5%. Even proactive refunds count toward that total, just like chargebacks.
That six-month monitoring period applies to each merchant account rather than the company as a whole, meaning switching acquirers, adding a legal entity, or expanding into a new market can restart the clock for legitimate platforms with complex payment structures, creating additional scrutiny even when those accounts exist for ordinary business reasons.
The Redundancy Problem
Many established platforms in this vertical run multiple merchant accounts across multiple acquiring banks. That's not necessarily evasion; it can be basic business continuity. But under SMMP, a new account can open a fresh six-month monitoring window, and a company with clean operations and multiple MIDs may look structurally similar, on paper, to one opening accounts to outrun a bad number.
That creates uncertainty for legitimate merchants that rely on redundancy across multiple accounts and MIDs. The distinction between redundancy and evasion should be established before an investigation begins through proper underwriting, a clear understanding of the business by acquiring partners and transparency around how volume moves across the portfolio.
In my experience, merchants' biggest concern isn't cost; it's uncertainty. Will the account stay live? Will it stay healthy? Addressing that uncertainty starts with making sure acquiring partners understand why the account structure exists in the first place.
Why This Vertical
SMMP isn't targeted at any one industry by design, but Mastercard's guidance specifically identifies adult content and dating platforms for closer attention. Discretion needs and billing descriptor confusion are common in these verticals, and both can contribute to the refund and dispute activity SMMP is designed to detect. That can make ordinary business friction look like a risk signal on paper.
I don't necessarily consider these businesses high-risk. I see them as complex or specialty merchants that require a more careful approach to finding the right partners, banks and technology. That added complexity doesn't necessarily translate to greater risk.
Getting Ahead of the Triggers
Merchants that want to stay ahead of SMMP need to understand what can trigger an investigation and monitor those signals closely. That means knowing where every MID sits relative to the combined 5% refund-and-chargeback threshold, which accounts are within their six-month monitoring window and which newer accounts are approaching the 500-transaction floor that makes them eligible for review.
Just as important is understanding what sits behind those numbers. Track refund causes individually so you have something concrete to address, use billing descriptors customers recognize, and maintain a documented compliance file before an investigation begins rather than assembling one during a 72-hour scramble.
How merchants respond matters, too. Delaying refunds to protect a ratio, making cancellation difficult, splitting volume across MIDs to dilute a number or opening accounts with incomplete underwriting can create the very patterns SMMP is designed to detect.
Where Relationships Decide Outcomes
The 72-hour investigation window belongs to the acquirer, not the merchant. That makes the acquiring relationship especially important when an SMMP signal appears. An acquirer that already understands the merchant's business model, knows why its account structure exists and has the underwriting documentation to support it is better positioned to evaluate a potential false positive.
That preparation should begin before an application reaches the bank. For age-gated products, for example, age verification and appropriate disclosures should already be in place. It's far better to address potential concerns during underwriting than explain them after an investigation begins.
The same principle applies to merchants operating across multiple accounts or acquiring banks. Clear documentation, transparent account structures and strong acquiring relationships can help ensure an investigation begins with an understanding of the business rather than questions about who the merchant is and why its accounts are structured that way.
SMMP is the latest example of increasingly close merchant monitoring by card networks. Merchants that treat trigger management, compliance and acquiring relationships as an ongoing responsibility will be better prepared not only for SMMP, but for whatever changes come next.
Len Garcia is Chief Sales Officer at Centrobill, where he works with merchants across the adult, dating and subscription-commerce verticals on payment processing, risk and compliance strategy.
