Comprehensive onboarding guidelines and compliance requirements for merchants
Effective Date: November 22, 2025 | Compliance mandatory for all merchants
Merchant Requirements and Onboarding Guidelines
First Class Payments Inc. (1Klas)
Effective Date: 22/11/2025
Last Updated: 22/11/2025
Introduction
This document sets forth the comprehensive requirements, documentation standards, and compliance obligations for merchants seeking to establish a business relationship with First Class Payments Inc., operating as 1Klas ("1Klas," "we," "us," or "our").
Purpose: These requirements are established to ensure compliance with payment card network rules (Visa, MasterCard), applicable laws and regulations, anti-money laundering (AML) requirements, know-your-customer (KYC) obligations, and 1Klas's internal risk management policies.
Applicability: All merchants must satisfy the general requirements outlined herein, as well as any industry-specific or merchant category code (MCC) specific requirements applicable to their business operations.
Binding Nature: Compliance with these requirements is mandatory for onboarding and ongoing maintenance of merchant accounts. Failure to meet or maintain these standards may result in application rejection, account suspension, or termination.
Table of Contents
General Requirements for All Merchants
Dating Services (MCC 7273, 8641)
Internet Shops (MCC 5399, 5655, 5945)
Tobacco and E-Cigarettes (MCC 5993)
Telecommunications (MCC 4814, 4816)
Apartment Rental Services (MCC 6513, 7211)
Ticket Services (MCC 7922)
File Sharing and Hosting Providers (MCC 4816)
Gambling (MCC 7995)
Forex Trading (MCC 6211)
Gaming Services (MCC 7841, 7994)
Travel Services (MCC 4722, 5962)
Mail Order/Telephone Order (MOTO)1. General Requirements for All Merchants
1.1 Corporate Documentation
All merchants must provide the following corporate and legal documentation during the onboarding process:
Incorporation and Constitutional Documents:
Certificate of Incorporation or equivalent formation document
Articles of Association or equivalent organizational documents
Memorandum of Association (where applicable)
Current Shareholder Register showing all shareholders and their ownership percentages
Extract from the corporate register regarding directors and the company, dated no older than fifteen (15) days from submission
Identification and Ownership:
Certified copies of passports or government-issued identification for:
All persons with signing authority on the merchant account
All beneficial owners (individuals owning 25% or more of the company)
All directors and officers
Proof of residential address for all identified individuals (utility bills, bank statements, or government-issued documents dated within the last 90 days)
Banking and Financial Information:
Complete banking details for settlement and payout purposes
Bank reference letter or account statement (if requested)
Previous merchant processing statements or references from prior acquiring banks (where applicable)
Business Information:
Completed and signed 1Klas Merchant Questionnaire
Detailed business description and business model explanation
Organizational chart showing corporate structure and beneficial ownership
Business licenses and permits (as applicable to the industry)
1.2 Website Requirements
All merchant websites must meet the following minimum standards:
Operational Standards:
Fully functional, operational website (not under construction or development)
Secure Sockets Layer (SSL) certificate installed and properly configured (HTTPS)
Professional design and user experience appropriate for the business type
Clear navigation and accessible information
Required Pages and Information:
Contact Information Section must include:
Company legal name with registration number
Physical business address (not a P.O. Box)
Email address for customer inquiries
Telephone number for customer support
All other relevant company details
Terms of Use / Terms and Conditions:
Clear and comprehensive terms governing the use of the website and services
Easily accessible from the main page (typically in footer)
Written in clear, understandable language
Cancellation and Refunds Policy:
Detailed explanation of cancellation procedures
Clear refund policy including timeframes and conditions
Contact information for processing cancellations and refunds
Mandatory under Visa and MasterCard operating rules
Privacy Policy / Confidentiality Agreement:
Comprehensive privacy policy explaining data collection, usage, and protection
Compliance with applicable data protection laws (GDPR, PIPEDA, etc.)
Information on how customer data is stored and secured
Payment Methods Description:
Clear description of accepted payment methods
List of available currencies for transactions
Information on payment processing and security
Copyright Notice:
Proper copyright attribution for website content
Intellectual property rights statements
Payment Card Network Logos:
Visa and MasterCard logos prominently displayed on the main page
Logos must be current and properly used in accordance with brand guidelines
Mandatory Checkbox Requirement:
Critical: At the point of payment, there must be a mandatory checkbox (tick box) that users must actively select to confirm they have read and agree to:
Terms and Conditions
Refund and Cancellation Policy
Privacy Policy
This checkbox cannot be pre-selected; users must affirmatively check it
1.3 Compliance and Risk Management
Anti-Money Laundering (AML) and Know Your Customer (KYC):
Merchants must implement appropriate AML and KYC procedures for their customers
Documentation of customer identification and verification processes
Policies for detecting and reporting suspicious activity
Record-keeping procedures in accordance with applicable laws
Data Protection and Security:
Compliance with Payment Card Industry Data Security Standard (PCI DSS) requirements
Secure handling and storage of customer personal data
Incident response and data breach notification procedures
Privacy impact assessments (where required)
Transaction Monitoring:
Systems and procedures for monitoring transactions for fraud and suspicious activity
Chargeback management and dispute resolution procedures
Customer complaint handling mechanisms
1.4 Additional General Requirements
Language Requirements:
At least one official language of the European Union must be available on the website (where the merchant operates in or serves EU markets)
This requirement applies to EU-incorporated entities or those serving EU customers
Note: Not all acquiring banks enforce this requirement, but it is recommended for cross-border operations
Business Registration:
For many merchant categories, the company must be incorporated in the European Union, Canada, or other approved jurisdictions
Specific jurisdiction requirements vary by merchant category (see sections below)
Testing and Verification:
Merchants may be required to provide test accounts, demo access, or sample products for verification purposes
1Klas reserves the right to conduct test transactions to verify website functionality and payment processing
2. Dating Services (MCC 7273, 8641)
2.1 MasterCard Registration Program (MRP)
Program Requirement:
All dating merchants must be registered in the MasterCard Registration Program (MRP) for high-risk businesses
Registration Cost: $500 USD annual fee per merchant/URL
Each merchant entity and each unique URL must be registered separately
It is not possible to register a single Merchant ID (MID) for multiple merchant category codes (MCCs)
Registration fee must be paid by the merchant or the Internet Payment Service Provider (IPSP)
2.2 Jurisdiction and Incorporation
Company Incorporation:
The merchant company must be incorporated in the European Union
2.3 Age Verification and Model Documentation
Age Verification System:
Detailed, written description of the age verification procedure implemented on the platform
Documentation of how the platform ensures all models/content creators and users are of legal age (18+ or as required by jurisdiction)
Technical specifications of the age verification system
Policies for handling age verification failures
Model/Content Creator Documentation:
Individual agreements with each model or content creator who has an account on the website
Certified copy of passport or government-issued identification for each model
Proof of age for all models (birth certificates, official ID documents)
Model consent forms and rights agreements
Records must be maintained and updated regularly
2.4 Test Account
Requirement:
Merchant must provide a fully functional test account funded with credits
Test account must demonstrate all features and functionalities of the platform
1Klas will use the test account to verify compliance with requirements
2.5 Additional Documentation
Financial and Operational Documentation:
Invoices for the purchase of goods (if applicable)
Contracts with service providers (hosting, payment processing, content delivery, etc.)
URL with comprehensive company contact information and registration data
2.6 Website-Specific Requirements
In addition to the general website requirements outlined in Section 1.2, dating service websites must include:
Age Restriction Notices:
Prominent notice of age restrictions (18+ or as legally required)
Clear terms and conditions regarding user identification and age verification
Warning messages and age gates at entry points
User Monitoring and Safety:
Description of the user monitoring system, including:
IP address tracking and geo-blocking capabilities
Country restrictions and compliance measures
Document verification for user-uploaded identification
Content moderation policies and procedures
Personal Data Handling:
Detailed policy description explaining how users' personal data are stored, processed, and protected
Specific information on age verification data retention and security
Compliance with GDPR and other applicable data protection laws
Additional Compliance Measures:
Clear community guidelines and prohibited content policies
Mechanisms for reporting abuse, exploitation, or illegal content
Cooperation procedures with law enforcement agencies
2.7 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Any additional licenses or permits required for operating an adult or dating platform in the jurisdiction of incorporation or operation
3. Internet Shops (MCC 5399, 5655, 5945, and Similar)
3.1 Jurisdiction and Incorporation
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions as determined by 1Klas
3.2 Product and Service Documentation
Detailed Business Information:
Comprehensive product catalog or detailed service descriptions
Clear pricing information for all products and services offered
Product sourcing information and supply chain documentation
Quality assurance and product safety compliance documentation (where applicable)
Supplier and Vendor Documentation:
Invoices for the purchase of goods from suppliers
Contracts with service providers, manufacturers, or wholesalers
Proof of authorized distribution (for branded or licensed products)
Import/export documentation (if applicable)
3.3 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, internet shop websites must include:
Product Information:
Detailed product descriptions including specifications, dimensions, materials, etc.
High-quality product images
Clear and accurate pricing information in the transaction currency
Availability and stock information
Delivery and Shipping:
URL with comprehensive Delivery Options and Policy
Shipping costs, delivery timeframes, and geographic restrictions
Tracking information provisions
International shipping policies (if applicable)
Privacy and Data Protection:
URL with detailed Privacy Policy
Explanation of how customer data is collected, used, and protected
Information on third-party data sharing (payment processors, shipping partners, etc.)
3.4 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1.
3.5 Additional Considerations
Language Requirement:
Website should be available in at least one official language of the European Union (for EU-serving merchants)
Note: Not all acquiring banks enforce this requirement
4. Tobacco and E-Cigarettes (MCC 5993)
4.1 MasterCard Registration Program (MRP)
Program Requirement:
All tobacco merchants must be registered in the MasterCard Registration Program (MRP) with MCC 5993
Registration Cost: $500 USD annual fee
Registration fee must be paid by the merchant or the Internet Payment Service Provider (IPSP)
4.2 Jurisdiction and Licensing
Company Incorporation:
The merchant company must be incorporated in the European Union
Excise Goods License:
Critical Requirement: The merchant must possess a valid license for the sale of excisable goods (tobacco products) in each and every country where the products will be offered for sale or delivered
Licenses must be current, valid, and in good standing
Copies of all licenses must be provided during onboarding
Any changes, renewals, or revocations of licenses must be reported immediately to 1Klas
4.3 Age Verification at Delivery
Customer Age Verification:
Detailed description of the process for verifying customer age at the time of delivery
Procedures to ensure customers are of legal age to purchase tobacco products (18+ or as required by jurisdiction)
Documentation of delivery partner agreements requiring age verification
Training materials for delivery personnel
Record-keeping procedures for age verification confirmations
4.4 Geographic Restrictions and BIN Blocking
Important Notice:
When selling tobacco products over the internet, 1Klas (as Payment Service Provider) will only enable Bank Identification Number (BIN) processing for those countries where the merchant holds a valid license to sell excisable goods
Payment cards from all other countries will be blocked by the Anti-Fraud system
Geo-blocking must be implemented at multiple levels (website access, payment processing, shipping)
4.5 E-Cigarettes Specific Requirements
Classification and Treatment:
E-Cigarettes Without Nicotine:
Products that do not contain nicotine or nicotine-containing liquids may be treated as electronic goods
Subject to standard internet shop requirements (see Section 3)
No tobacco license required (verify with local regulations)
E-Cigarettes With Nicotine:
Products containing nicotine are subject to certification as excise goods
Require appropriate licenses for sale and distribution
Subject to all restrictions and requirements applicable to tobacco products
Note: In some European countries, it may be permissible to sell nicotine-containing e-cigarettes without a specific license; such cases must be investigated and approved by 1Klas's AML/Compliance department on a case-by-case basis
4.6 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Details of all jurisdictions where sales are permitted
Agreements with logistics and delivery partners
Insurance documentation (product liability, business liability)
4.7 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, tobacco merchant websites must include:
Age Verification and Warnings:
Mandatory age verification gateway before accessing the website
Prominent health warnings as required by applicable law
Clear statement of legal age requirements
Geo-blocking notices for restricted jurisdictions
Product Information:
Clear product descriptions including nicotine content
Health and safety warnings
Proper labeling information
Compliance with tobacco advertising regulations
4.8 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
All tobacco/excise goods licenses for each jurisdiction of operation
Compliance certifications from regulatory authorities
Health and safety compliance documentation
5. Telecommunications (MCC 4814, 4816)
5.1 Jurisdiction and Licensing
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations)
Telecommunications License:
Critical Requirement: Merchant must hold a valid telecommunications license authorizing the specific business activities being conducted
License must be issued by the appropriate regulatory authority in the jurisdiction of operation
License must be current, in good standing, and cover the scope of services offered
Copy of the telecommunications license must be provided during onboarding
5.2 Test Account
Requirement:
Merchant must provide a fully functional test account
Test account must demonstrate all telecommunications services offered
1Klas will use the test account to verify service quality, billing accuracy, and compliance
5.3 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Service descriptions and rate cards
Network diagrams or technical documentation (if requested)
Compliance documentation from telecommunications regulators
5.4 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, telecommunications service websites must include:
Service Information:
Clear description of telecommunications services offered (VoIP, calling cards, prepaid minutes, SMS services, etc.)
Transparent pricing and rate information
Coverage areas and service availability
Quality of service guarantees (if any)
Regulatory Compliance:
Compliance with telecommunications regulations in operating jurisdictions
Emergency services availability and limitations (for VoIP services)
Number portability information (if applicable)
5.5 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Telecommunications operating license
Regulatory compliance certifications
Interconnection agreements (if applicable)
6. Apartment Rental Services (MCC 6513, 7211)
6.1 Jurisdiction Requirements
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions
6.2 Property Documentation
Critical Requirement - Property Ownership or Rights:
Contracts with property landlords or property owners demonstrating the legal right to market and rent the properties
Documentation proving ownership of real estate (if the merchant owns the properties), including:
Title deeds or land registry documents
Property ownership certificates
Notarized proof of ownership
Property management agreements (if acting as a property manager)
Vacation rental licenses or permits (where required by local regulations)
6.3 Test Account
Requirement:
Merchant must provide a test account with access to the booking platform
Test account must demonstrate the full booking, payment, and confirmation process
Sample property listings must be available for review
6.4 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
List of all properties available for rental
Insurance documentation (liability insurance, property insurance)
Compliance with short-term rental regulations (Airbnb laws, hotel taxes, etc.)
6.5 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, apartment rental websites must include:
Property Listings:
Detailed property descriptions with accurate information
High-quality photographs of properties
Clear pricing information (nightly rates, cleaning fees, security deposits, etc.)
Availability calendars
Property amenities and features
Check-in and check-out procedures
Booking and Cancellation Policies:
Clear booking procedures and confirmation processes
Detailed cancellation policy with applicable timeframes
Security deposit and damage policy
Guest responsibilities and house rules
Legal Compliance:
Compliance with local short-term rental regulations
Tax collection and remittance information (occupancy tax, tourism tax, etc.)
Safety and accessibility information
Dispute resolution procedures
6.6 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Property ownership documents or landlord agreements for all listed properties
Business licenses or permits required for rental operations
Insurance certificates
7. Ticket Services (MCC 7922)
7.1 Jurisdiction Requirements
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions
7.2 Event Organizer and Venue Agreements
Critical Requirement - Authorization Documentation:
For Concert Tickets:
Agreements with concert organizers, promoters, or venues authorizing the merchant to sell tickets
Proof of official ticketing partnership or authorized reseller status
For Sports Tickets:
Agreements with sports clubs, leagues, or their official representatives/agents
Verification that the merchant is listed on the website of the sports organization as an authorized ticket seller
Examples: official partnerships with football clubs, hockey teams, or governing sports bodies
For Other Events:
Authorization agreements with event organizers, venues, or rights holders
Proof of legitimate ticket inventory sources
7.3 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Inventory management system documentation
Pricing and fee structure transparency
Relationships with primary ticket sellers or venues
7.4 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, ticket service websites must include:
Event Information:
Comprehensive event details (date, time, location, performers, etc.)
Seating charts and seat selection tools
Ticket pricing clearly displayed (including all fees and charges)
Ticket delivery methods and timing
Authenticity and Guarantees:
Ticket authenticity guarantee
Clear statement on whether tickets are primary or resale
Replacement policy for lost or stolen tickets
Entry guarantee or refund policy
Legal Compliance:
Compliance with ticket resale laws and regulations
Price transparency (total cost displayed before purchase)
No hidden fees
Clear disclosure of markup or service fees
7.5 Anti-Fraud Measures
Requirements:
Systems to prevent fraudulent ticket sales
Barcode and ticket verification processes
Protection against counterfeit tickets
Cooperation with event organizers on security matters
7.6 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
All agreements with event organizers, sports clubs, venues, or official representatives
Proof of authorized ticket seller status
Ticket resale licenses (where required)
8. File Sharing and Hosting Providers (MCC 4816)
8.1 Jurisdiction Requirements
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions
8.2 Content Monitoring and Moderation
Critical Requirement - Content Monitoring System:
Detailed description of the content monitoring system implemented to oversee files, content, and materials uploaded by users or clients
Technology and procedures used for:
Automated content scanning and filtering
Manual review processes
Detection of illegal or prohibited content
Removal of violating content
Prohibited Content Detection:
Systems specifically designed to detect and prevent:
Child sexual abuse material (CSAM)
Copyright-infringing materials
Malware, viruses, and malicious software
Content violating terms of service
8.3 Law Enforcement Cooperation
Required Documentation:
Detailed description of the merchant's policies and procedures for responding to requests from law enforcement agencies
Process for handling takedown notices, subpoenas, and court orders
Legal compliance procedures
Data retention and disclosure policies
Designated points of contact for law enforcement
8.4 Test Account
Requirement:
Merchant must provide a fully functional test account
Account must allow 1Klas to evaluate the platform, upload test files, and verify content moderation processes
8.5 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Content policies and community guidelines
Intellectual property infringement policies
Data protection and privacy policies
8.6 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, file sharing and hosting provider websites must include:
Terms of Use - Enhanced Requirements:
Explicit prohibition and criminal liability statement for production and dissemination of child sexual abuse material (CSAM)
Clear terms prohibiting illegal content including:
Child exploitation materials
Rape depictions
Bestiality
Violence and exploitation
Incest depictions
Consequences for violations (account termination, reporting to authorities, legal action)
Warning Messages and Content Notices:
Warning message placement adjacent to sensitive or adult content categories
Age verification mechanisms for adult content
Clear content categorization and labeling
DMCA Compliance:
Digital Millennium Copyright Act (DMCA) compliance policy prominently displayed
Designated DMCA agent contact information
Procedures for filing copyright infringement notices
Counter-notification procedures
Statement of criminal liability for production and dissemination of technology, devices, or services that violate intellectual property rights
Repeat infringer policy
User Safety and Reporting:
Mechanisms for users to report illegal or prohibited content
Abuse reporting procedures
Transparency about content removal decisions
8.7 Legal and Compliance Requirements
Mandatory Compliance Areas:
Compliance with child protection laws
Copyright and intellectual property laws (DMCA, EU Copyright Directive, etc.)
Data protection and privacy laws (GDPR, etc.)
Cybercrime and computer misuse laws
Cooperation with law enforcement on criminal investigations
8.8 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Content moderation policies and procedures documentation
Law enforcement cooperation protocols
DMCA agent registration with the U.S. Copyright Office (if applicable)
Insurance documentation (errors and omissions, cyber liability)
9. Gambling (MCC 7995)
9.1 Jurisdiction and Licensing Requirements
Company Incorporation:
The merchant company must be incorporated in the European Union
Gambling License - Critical Requirement:
Approved Gambling Licenses include licenses issued by:
European Union Member States such as:
Malta Gaming Authority (MGA)
UK Gambling Commission
Gibraltar Regulatory Authority
Curaçao eGaming
Isle of Man Gambling Supervision Commission
Other approved jurisdictions as determined by 1Klas
Documentation Requirements:
Original or certified copy of the gambling/gaming license
The documentation must clearly demonstrate that the applying merchant company is officially owned by, or is a subsidiary of, the company holding the gambling license
License must be current, valid, and in good standing
License must cover the specific types of gambling activities being offered
Latvian Market-Specific Requirement:
If operating in or serving customers in the Latvian market, or engaging with Latvian companies, the merchant must also obtain a gambling license from the Lotteries and Gambling Supervision Inspection of Latvia
9.2 Fraud Management and Compliance Documentation
Required Policies and Procedures:
Know Your Customer (KYC) Procedures:
Detailed KYC policies and implementation procedures
Customer identity verification methods
Age verification processes (ensuring customers are of legal gambling age)
Document verification procedures
Anti-Money Laundering (AML) Procedures:
Comprehensive AML policies and compliance program
Transaction monitoring procedures
Suspicious activity reporting protocols
Record-keeping requirements
Payout Procedures and Controls:
Detailed payout policies and procedures
Verification processes before releasing winnings
Large payout approval workflows
Fraud detection mechanisms
Responsible Gambling Measures:
Self-exclusion programs
Deposit limits and betting limits
Problem gambling identification and intervention procedures
Links to gambling addiction support resources
9.3 Website Ownership and Domain Registration
Verification Documentation:
Formal confirmation letter on the merchant's official letterhead, signed by a Director or Company Secretary, stating that the gambling website is wholly owned and operated by the merchant company
Domain registration document ("WHOIS" information) clearly stating the official owner of the domain name
Verification that the merchant entity matches the domain registrant or is authorized to use the domain
9.4 Banking References
Previous Processing History:
Ability to provide reference letters, account statements, or processing history from previous acquiring banks or payment processors
Information to be provided upon request by 1Klas
Used to assess merchant history, processing volumes, chargeback ratios, and compliance track record
9.5 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Game rules and odds information
Random Number Generator (RNG) certification (if applicable)
Software provider agreements and licenses
9.6 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, gambling websites must include:
Legal Warnings and Notices:
Jurisdiction Legality Warning:
"Internet gambling may be illegal in the jurisdiction in which you are located. If so, you are not authorized to use your payment card to complete this transaction."
Cardholder Responsibility Statement:
Clear statement informing cardholders of their responsibility to know and comply with the laws concerning online gambling in their country of domicile or residence
Prohibition of Minor Participation:
Prominent statement prohibiting the participation of minors in gambling activities
Clear age restrictions (e.g., "You must be 18 years or older to use this site")
Age verification mechanism
Game Information and Rules:
Complete Game Descriptions:
Detailed rules of play for all games offered
Odds information and house edge disclosure (where required)
Explanation of betting options
Cancellation Policies:
Clear policies on bet cancellation or void bets
Circumstances under which bets may be voided
Timeframes for disputing bets
Payout Policies:
Complete description of payout procedures
Withdrawal methods and processing times
Minimum and maximum withdrawal amounts
Verification requirements for payouts
Fees associated with withdrawals (if any)
Responsible Gambling:
Self-exclusion options
Deposit and betting limits
Links to problem gambling support organizations
Responsible gambling tips and information
Geo-Blocking and Restrictions:
Clear statement of restricted jurisdictions
Geo-blocking implementation to prevent access from prohibited countries
Terms prohibiting use of VPNs or proxies to circumvent restrictions
9.7 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Copy of gambling license from an approved jurisdiction
Copy of Latvian gambling license (if applicable)
KYC, AML, and payout procedure documentation
Website ownership confirmation letter
Domain registration documentation
RNG certifications (if applicable)
Game provider licenses
10. Forex Trading (MCC 6211)
10.1 Jurisdiction and Licensing
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions
Forex Trading License or Registration:
Critical Requirement: Merchant must hold a valid license for forex trading operations OR
Be officially registered with the appropriate financial regulatory authority OR
Hold membership in a recognized quality assurance organization (e.g., Kroufr or similar independent association)
Examples of Acceptable Regulatory Licenses:
Financial Conduct Authority (FCA) - United Kingdom
Cyprus Securities and Exchange Commission (CySEC) - Cyprus
BaFin - Germany
AMF - France
Or equivalent regulatory bodies in other EU member states
10.2 Compliance and Risk Management Documentation
Required Policies and Procedures:
Anti-Money Laundering (AML) Policy:
Comprehensive AML policies and compliance program
Customer due diligence (CDD) procedures
Enhanced due diligence (EDD) for high-risk customers
Transaction monitoring and suspicious activity reporting
Record-keeping requirements
Know Your Customer (KYC) Policy:
Detailed KYC policies and implementation procedures
Customer identity verification methods
Document verification procedures
Ongoing customer monitoring
PEP (Politically Exposed Person) screening
Clear Company Structure:
Organizational chart showing the complete corporate structure
Identification of all beneficial owners (25% or more ownership)
Parent companies, subsidiaries, and affiliated entities
Management structure and key personnel
10.3 Liquidity Provider Agreements
Critical Requirement:
Liquidity agreement with CFH Clearing (or other approved liquidity providers)
Demonstration of adequate liquidity to support client trading activities
Proof of financial stability and capital adequacy
10.4 Beneficial Owner Documentation
Utility Bills for Business Owners:
Recent utility bills (electricity, water, gas, internet) for all beneficial owners
Bills must be dated within the last 90 days
Used for proof of residential address verification
10.5 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Trading platform information and technology providers
Risk disclosure documents provided to clients
Client agreements and terms of service
Evidence of segregated client accounts (if required by regulation)
10.6 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, forex trading websites must include:
Regulatory Information:
Prominent display of regulatory license number and issuing authority
Links to regulatory body websites for verification
Client fund protection information
Investor compensation scheme information (if applicable)
Risk Warnings and Disclosures:
Clear and prominent risk warnings regarding forex trading
Disclosure that forex trading involves significant risk of loss
Statement that leveraged trading can result in losses exceeding initial investment
Past performance disclaimers
US Citizen Prohibition:
Critical Requirement: Policy explicitly prohibiting the registration and participation of United States citizens and residents of U.S. territories
This policy must be clearly stated in the Terms of Use
Typically placed in the footer of all pages for visibility
Geo-blocking must be implemented to prevent access from U.S. IP addresses
Trading Information:
Available currency pairs and instruments
Leverage ratios offered
Spreads and commission structures
Margin requirements
Execution policies
Educational Resources:
Trading tutorials and educational materials
Risk management guides
Glossary of forex trading terms
10.7 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Copy of forex trading license or regulatory registration
AML and KYC policy documents
Company structure documentation with beneficial ownership
Liquidity agreement with approved provider
Utility bills for all beneficial owners
Evidence of capital adequacy
Professional indemnity insurance documentation (if applicable)
11. Gaming Services (MCC 7841, 7994)
11.1 Jurisdiction and Licensing
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions
Gaming License Requirements:
Critical Requirement: Merchant must hold a valid gaming license from an approved jurisdiction OR
Be officially registered with the appropriate gaming regulatory authority OR
Hold membership in a recognized industry quality assurance organization (e.g., Kroufr or similar independent association)
Additional Licensing for Specific Markets:
If operating with a financial institution payment provider or serving specific markets (e.g., Latvian market), additional licenses may be required in those jurisdictions
Compliance with local gaming regulations mandatory
11.2 Compliance and Risk Management Documentation
Required Policies and Procedures:
Anti-Money Laundering (AML) Policy:
Comprehensive AML policies and compliance program specifically tailored for gaming operations
Player due diligence procedures
Transaction monitoring for suspicious gaming patterns
Reporting protocols for suspicious activity
Know Your Customer (KYC) Policy:
Detailed KYC policies for player verification
Age verification processes (ensuring players meet minimum age requirements)
Identity document verification procedures
Ongoing player monitoring and account reviews
Clear Company Structure:
Organizational chart showing complete corporate structure
Identification of all beneficial owners (25% or more ownership)
Parent companies, subsidiaries, and affiliated entities
Management team and key personnel
11.3 Liquidity and Financial Documentation
Liquidity Agreement:
Liquidity agreement with CFH Clearing or other approved liquidity providers (if applicable to the type of gaming)
Demonstration of financial stability and ability to pay out player winnings
Capital adequacy documentation
11.4 Beneficial Owner Documentation
Utility Bills for Business Owners:
Recent utility bills for all beneficial owners
Bills must be dated within the last 90 days
Used for proof of residential address
11.5 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Gaming platform provider information
Random Number Generator (RNG) certification (for games of chance)
Fair gaming policies and procedures
Player protection measures
11.6 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, gaming service websites must include:
Regulatory Information:
Display of gaming license number and regulatory authority
Links to regulatory body for license verification
Responsible gaming information and resources
US Citizen Prohibition:
Critical Requirement: Policy explicitly prohibiting the registration and participation of United States citizens and residents of U.S. territories
This policy must be clearly stated in the Terms of Use
Typically placed in the footer of all pages
Geo-blocking implementation to prevent U.S. access
Game Information:
Complete game rules and instructions
Return to Player (RTP) percentages
Volatility information
Maximum win and loss limits
Player Protection:
Responsible gaming tools (deposit limits, self-exclusion, cooling-off periods)
Links to problem gambling support organizations
Age verification and minor protection measures
Fair play policies
Financial Information:
Deposit methods and processing times
Withdrawal procedures and timeframes
Bonus terms and conditions (wagering requirements, etc.)
Fee structures
11.7 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Copy of gaming license or regulatory registration
Additional jurisdiction-specific licenses (if applicable)
AML and KYC policy documents
Company structure documentation
Liquidity agreement
Utility bills for beneficial owners
RNG certification from accredited testing laboratory
Game fairness certifications
12. Travel Services (MCC 4722, 5962)
12.1 Jurisdiction Requirements
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions
12.2 Service Provider Agreements and Partnerships
Critical Requirement - Direct Contracts:
Contracts with flight operators, airlines, hotels, car rental companies, tour operators, and other travel service providers whose services are being offered (directly or indirectly) to customers
Proof of authorized agency or partnership status
Commission agreements or booking authorization letters
12.3 Industry Certifications and Memberships
Travel Industry Association Memberships:
Merchant or their contractual partner must hold certification or membership from recognized travel industry organizations, including but not limited to:
ECTAA (European Travel Agents' and Tour Operators' Associations)
ETOA (European Tour Operators Association)
IRU (International Road Transport Union)
ASTA (American Society of Travel Advisors) - www.asta.org
IATA (International Air Transport Association) - for airlines and authorized IATA agents
ABTA (Association of British Travel Agents) - for UK-based operators
Other nationally recognized travel industry associations
Reservation System Access:
Direct access to Computer Reservation Systems (CRS) such as Amadeus, Sabre, Galileo, or Worldspan (or access through an authorized partner)
Proof of CRS credentials and authorization
Booking system integration documentation
12.4 Financial Responsibility and Consumer Protection
Financial Accountability:
Clearly stated financial responsibility provisions in contracts with agents and partners
Evidence of bonding, insurance, or trust account arrangements to protect customer funds
Compliance with package travel regulations (if applicable)
Consumer Protection Measures:
Insolvency protection or bonding (as required by EU Package Travel Directive or similar regulations)
Customer refund protection mechanisms
Financial failure insurance
12.5 Customer Data Management
Data Collection and Storage:
Availability of travel agency forms on the website where customers can input personal data (passenger information, passport details, contact information, etc.)
Demonstrated ability to securely store customer data in compliance with data protection laws
Data retention policies
Privacy and security measures
12.6 Banking References
Processing History:
Ability to provide reference letters, account statements, or processing history from previous acquiring banks or payment processors (upon 1Klas's request)
Used to assess merchant reliability, processing volumes, chargeback history, and compliance track record
12.7 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Sample itineraries or travel packages offered
Supplier agreements and authorizations
Insurance documentation (professional indemnity, travel insurance partnerships)
12.8 Website-Specific Requirements
In addition to the general website requirements in Section 1.2, travel service websites must include:
Booking and Reservation System:
Fully functional online booking engine
Real-time availability and pricing
Secure payment processing
Booking confirmation and e-ticket delivery
Travel Information:
Detailed descriptions of destinations, accommodations, and services
Transparent pricing showing all fees, taxes, and charges
Travel dates, duration, and itineraries
Inclusions and exclusions clearly stated
Terms and Conditions - Enhanced:
Booking conditions and payment terms
Detailed cancellation and change policies
Travel insurance information and recommendations
Passport, visa, and health requirements
Terms regarding flight changes, delays, or cancellations
Consumer Protection Information:
Financial protection information (bonding, insurance, trust accounts)
ATOL protection (if applicable in the UK)
Package Travel Directive compliance information
Emergency contact information for travelers
Supplier Information:
Information about airline partners, hotel chains, and service providers
Disclaimers regarding services provided by third parties
12.9 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.1, plus:
Contracts with airlines, hotels, tour operators, and other travel service providers
Travel industry association membership certificates (ECTAA, ETOA, IATA, etc.)
CRS access credentials and authorization
Financial responsibility documentation (bonding, insurance, trust accounts)
Business liability insurance
Previous acquiring bank references (if requested)
13. Mail Order/Telephone Order (MOTO)
13.1 Jurisdiction Requirements
Company Incorporation:
The merchant company must be incorporated in the European Union (for EU operations) or other approved jurisdictions
13.2 Payment Gateway and Transaction Processing
Sample Page and Gateway Screenshots:
Detailed screenshots or sample pages of the payment gateway interface used by telemarketers or order-takers
Must show fields for capturing:
Customer first name and last name
Full address (street, city, postal code)
Country
Card type (Visa, MasterCard, etc.)
Credit card number
CVV2/CVC2 security code
Card expiration date
Invoice number and transaction date
Mandatory CVV2 Usage:
Critical Requirement: CVV2/CVC2 code must be collected and used in all authorization requests
This is mandatory for MOTO transactions to reduce fraud risk
System must be configured to require CVV2 for transaction approval
13.3 Marketing and Sales Documentation
Marketing Strategy Documentation:
Detailed description of the marketing strategy used to attract customers
Media channels utilized, including:
Television advertising
Radio advertising
Print advertising (newspapers, magazines)
Direct mail campaigns
Email marketing
Online advertising
Telemarketing lists and sources
Sample Advertisement:
Copy of a typical advertisement used by the company
Must show how products/services are presented to customers
Pricing and offer details
Call-to-action and contact information
13.4 Sales Process Documentation
Sales Conversation Recording or Script:
Audio recording (tape, WAV file, or MP3) of a typical sales conversation between telemarketer and customer OR
Detailed written script used by telemarketers during sales calls
Must demonstrate:
Product presentation
Pricing disclosure
Terms and conditions communication
Payment information collection
Customer consent verification
13.5 Order Confirmation and Invoicing
Sample Invoice or Order Confirmation:
Copy of a typical invoice, receipt, or order confirmation provided to customers
Must include:
Company name and contact information
Itemized product/service descriptions
Pricing and applicable taxes
Payment information
Delivery information
Customer support contact details
Delivery Note:
Sample delivery note or shipping confirmation
Proof of delivery mechanisms
Tracking information provided to customers
13.6 Additional Documentation
Required Information:
URL with comprehensive company contact information and registration data
Customer service policies and procedures
Refund and return procedures for MOTO transactions
Dispute resolution processes
13.7 Website Requirements (If Applicable)
If the merchant also has an online presence, all standard website requirements from Section 1.2 apply, plus:
MOTO-Specific Information:
Telephone ordering information and hours of operation
Toll-free or customer service phone numbers
Mail order address (if accepting orders by mail)
Statement that CVV2 is required for all telephone and mail orders
13.8 Compliance and Risk Management
Fraud Prevention Measures:
Address Verification Service (AVS) usage
CVV2 verification for all transactions
Order verification procedures for high-risk or high-value transactions
Velocity checks and transaction monitoring
PCI DSS Compliance:
Compliance with Payment Card Industry Data Security Standard (PCI DSS) for MOTO environments
Secure handling of cardholder data
Employee training on data security
Call recording security and retention policies
13.9 Corporate and Legal Documentation
Merchants must provide all standard corporate documentation as outlined in Section 1.2, plus:
Gateway screenshots showing all required data fields
Marketing strategy documentation
Sample advertisements
Sales script or conversation recording
Sample invoices and delivery notes
Evidence of PCI DSS compliance
Telemarketing licenses (if required by jurisdiction)
General Notes and Additional Information
Language Requirements
European Union Language Requirement:
For merchants incorporated in the EU or serving EU customers, at least one official language of the European Union should be available on the website
This requirement is intended to prevent cross-border licensing violations
Important Note: Not all acquiring banks strictly enforce this requirement; however, it is recommended for best practices and broader market access
Fees and Costs
MasterCard Registration Program (MRP):
High-risk merchants requiring MRP registration (dating services, tobacco, gambling, etc.) must pay an annual fee of $500 USD per merchant/URL
This fee is in addition to standard processing fees
Responsibility for payment must be clearly established (merchant or IPSP)
Ongoing Compliance
Periodic Reviews:
All merchants are subject to periodic compliance reviews
Documentation must be kept current and provided upon request
Changes in business model, ownership, licensing, or operations must be reported immediately
Website Monitoring:
1Klas reserves the right to monitor merchant websites for ongoing compliance
Non-compliance may result in suspension or termination
Document Submission
Format and Delivery:
All documents should be submitted in PDF format where possible
Certified copies or notarized documents may be required for certain items
Documents must be in English or accompanied by certified translations
Submission through secure channels designated by 1Klas
Application Processing
Review Timeline:
Applications will be reviewed within a reasonable timeframe
Incomplete applications may be delayed or rejected
Additional documentation or clarification may be requested
Approval Discretion:
1Klas reserves the right to approve or decline any merchant application at its sole discretion
High-risk merchant categories are subject to enhanced due diligence
Contact Information
For questions regarding merchant requirements, onboarding procedures, or documentation submission, please contact:
First Class Payments Inc. (1Klas)
Merchant Onboarding Department
Email: onboarding@1klas.com
Phone: +1 365 363 2288
Website: www.1klas.com
Questions About Merchant Onboarding?
Contact our merchant services team for assistance with onboarding or compliance questions: