“High Risk” clients are historically prone to higher levels of disputes, financial risk and liability as well as fraudulent activity.
In addition, entities which are beneficially owned by overseas Politically Exposed Persons (PEP’s) are also considered high risk as they may be subject to influence from overseas governments.
Before entering, extending, or renewing a merchant agreement, a sanctions screen must be performed against the Government by reference to DFAT consolidated list.
Azupay will do business with High-Risk industries, but they are assessed on a case-by-case basis.
All High-Risk customers are required to be passed through for review to Cuscal via the submission of a manual High Risk Merchant Form (HRMF). This is so Cuscal can be aware of the customers that are accessing both Azupay's and their systems and services.
In the initial Sales Stage (prior to a proposal being signed), if there is any doubt as to whether a High-Risk client will be accepted or not, an initial evaluation can be requested and carried out prior to moving into the full Due Diligence and the KYC (Know Your Customer) Process.

🏭 High Risk Industries

Current as of October 2025

High Risk Merchant Type / Industry	MCC
Buy Now Pay Later (within any Industry)	6052*
Business Services (not classified) e.g., Trusts	7399
Charities, Social Services	8398
Cigar / Online Tobacco Seller, Incl. “e-cigarette”	5993
Cyberlocker merchants	4816
Dating and escort services	7273
Drugs, Drug Proprietors, and Druggist’s Sundries including non-prescribed over the counter (OTC) products, e.g. vitamins, herbs and nutrients	5122, 5912
Games of skill such as daily fantasy sports gaming where consumers pay a fee to enter, and the outcome of the game is determined by skill instead of luck	5816
Gambling establishments including internet gambling – placing, receiving or transmitting a bet/wager Important: The Client MUST be registered and adhere to applicable regulations under the Gambling Sector (chapter 10) of the AML/CTF Rules & manage their risk exposure if they on-board gambling establishments. (Merchant is listed on ACMA website https://www.acma.gov.au/check-if-gambling-operator-lega)	9406, 7995, 7800, 7801, 7802
Gift Card Merchants	Not Coded
Video Tape Rental Stores	7841
Invoice management business e.g., processing and collection	8931
Internet adult digital content sites and providers	7273, 5967, 7841
High-risk Security Brokers and Dealers - Merchants that buy, sell, and broker high-risk securities, e.g. options	6211
Miscellaneous Personal Services – Not elsewhere classified	7299
Remote Stored Value Load - Merchant	6530, 6540
Payday Lenders (Licensed)	6062*
Pubs and Clubs including membership clubs, e.g. sports, recreation, golf courses, bars, taverns, cocktail lounges, night clubs.	7997, 5813
Wire Transfer / Money Order / Remittance Services and Non-Financial Institution Money Transfer Where the Client is a Wire Transfer/Money Order / Non-Financial Institution Money Transfer provider MUST be registered with AUSTRAC and implement an AML/CTF program. The client needs to be in business for at least 2 years, demonstrating a stable and established presence in the industry, and must have completed at least one independent review of their AML/CTF Program in accordance with AUSTRAC requirements by an accredited independent reviewer, and without significant issues identified. In addition, they need to have a local presence and have a minimum of 100 employees. Remittance services providers have additional conditions.	4829 6051 6211
Skill games Merchants	7994
Direct Marketing -Travel-Related Arrangement Services	5962
Direct Marketing -Outbound Telemarketing Merchant	5966
Direct Marketing - Inbound Teleservices Merchant (Adult content and services such as website subscriptions and video streaming)	5967
Bullion Dealers	No specific MCC
High-Value Investments: This can include, but is not limited to, diamonds and other gemstones, artworks, luxury vehicles, collectibles and antiques.	No specific MCC
Travel tour operators – avoiding travel to Azupay’s restricted countries, as per its AML/CTF Program.	No specific MCC
Crowd Funding	No specific MCC
Subscription "Negative Option" Merchants (card absent)	5968
Airlines and Travel Agents#	4511, 4722

*Category code created by Cuscal #Azupay noted (does not require Cuscal approval)#