High Risk Industries Under More Scrutiny
- “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)#