A Deep Dive into Visa’s VAMP Requirements

INSIGHTS FROM THE IDENZA/FYNTEK ROUNDTABLE: NAVIGATING THE NEW NORMAL

Visa’s new Acquirer Monitoring Program (VAMP) rules, which came into effect in October, represent one of the most significant shifts in fraud and risk management for merchants in years. Alexander Rea and Michael Sutton from Fyntek joined Idenza for an interactive roundtable to dissect these new rules, focusing on what they mean for businesses, particularly those operating in high-risk verticals such as gaming and sweepstakes.

Here is an overview of the most critical takeaways from the discussion and the essential steps merchants must take to ensure continuous compliance.

The Fundamental Shift in Fraud Liability

The core of the VAMP update is a major shift in liability. Where the industry previously focused on mitigating chargebacks post-transaction, the new rules fundamentally place the onus on merchants and acquirers to stop fraud before pre-authorization.

• Combined Ratios Mean Increased Scrutiny: VAMP is not just about fraud chargebacks. Visa is now combining the merchant ratio with both TC40 (fraud) and TC-15 (fraud and non-fraud contested transactions) reports. This holistic view demands a complete change in strategy.

• High Stakes: For any merchant whose combined ratio falls out of compliance, the consequences are severe: risk of losing payment processing, loss of their Merchant ID (MID), and potential placement on the permanent MATCH list. For businesses, this is an existential threat that can effectively halt operations.

Penalization of Low-Quality Traffic

A critical and often overlooked aspect of the new landscape is that issuers are now monitoring traffic quality across the board. Low-quality activity, even if it doesn't result in a chargeback, is being heavily penalized and can be more damaging to a merchant's standing than the actual fraud ratio.

• The Role of Declines and Enumeration: Tactics like enumeration (card testing), commonly used by fraud rings in sectors like gaming, lead to a high volume of card declines. Under the new rules, these frequent declines count against a merchant's standing, indicating a lack of control over the payment gateway.

• Promo Abuse: Non-fraudulent, yet abusive, traffic such as excessive promotion or bonus abuse, can also contribute to unwanted ratios and attract unwelcome scrutiny from issuers.

The Path Forward: Proactive Defense and Strategy

While the rules are tightening, with further enforcement expected in 2026, success hinges on proactive, adaptive strategies rather than simply fear of the unknown. Merchants must change their infrastructure to gain visibility and control.

Key Proactive Measures

• Real-Time Data is Non-Negotiable: Relying on monthly fraud reports is no longer adequate. Merchants must gain access to real-time data, including comprehensive TC40 reports and decline ratios, to monitor and immediately address issues like card testing as they occur.

• Active Fraud Management: The key to maintaining high conversion rates is to reward good traffic with less friction while catching high-risk traffic early. This requires sophisticated pre-authorization risk scoring to determine which transactions need to be routed through 3DS verification and which can proceed seamlessly.

• A Focus on Prevention: Solutions like the one offered by Idenza help operators achieve this balance by focusing on preemptive monitoring. By analyzing device behavior and semantics for pre-authorization risk scoring, they stop bad actors before they can contribute to costly TC40 or TC-15 entries.

• New Merchants Beware: New businesses are the most vulnerable to immediate malicious attacks. It is essential to have proactive fraud conversations and implement pre-authorization measures before going live, not after an attack has occurred.

Conclusion

Visa’s VAMP is not a temporary policy; it is a permanent change that dictates the necessity of a sophisticated, future-proof fraud strategy. Merchants must move past traditional, reactive chargeback mitigation and embrace proactive, real-time risk scoring. Partnering with expert payment processors and fraud management vendors like Fyntek and Idenza is the only way to successfully navigate this regulatory landscape, protect your MID, and secure your long-term operations.