“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

High Risk Merchant Type / Industry	MCC
Buy Now Pay Later (within any Industry)	No specific MCC
Business Services (not classified) e.g., Trusts	7399
Charities, Social Services	8398
Cigar / Online Tobacco Seller, Incl. “e-cigarette”	5993
Cyberlocker merchants	4816
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
Drugs, Drug Proprietors, and Druggist’s Sundries	5122, 5912
Gambling establishments, including internet gambling 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
High Risk Securities - Merchants that buy, sell, and broker high risk securities	6211
Miscellaneous Personal Services – Not elsewhere classified	7299
Payday Lenders (Licensed)	Not Coded
Pubs and Clubs – incl. Membership Clubs	7997, 5813
Wire Transfer / Money Order / Remittance Services and Non-Financial Institution Money Transfer Where the Client is a Wire transfer, Order / Non-Financial Institution Money Transfer provider it MUST be registered with AUSTRAC and implement an AML/CTF program. The client needs to be in business for at least 3 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 without significant issues identified. 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