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Key facts (as of 29 October 2026)
- Card-network role: Visa defines a payment facilitator as an entity that "deposits transactions or receives settlement on behalf of the Merchant but does not sell goods or services to cardholders".
- Descriptor rule: where a cardholder is sent to a high-risk internet payment facilitator to pay, the facilitator's name must appear in the merchant name field together with the sponsored merchant's name (Visa MDSM, October 2026).
- Registration: under the Visa Integrity Risk Program, acquirers must register third-party agents such as ISOs, payment facilitators and digital wallet operators that solicit high-risk merchants.
- Licence pressure: Turkey's central bank has revoked 15 payment and e-money licences in 2026 (15M review). Indonesia's central bank has warned PSPs they risk losing licences if involved in illegal transactions.
- Legal bans reach PSPs: Brazil's MP 1.394 bars payment institutions and payment-arrangement participants, including instant payments, from processing betting transactions. Colombia's Decree 0240 of 2026 bars PSPs from serving unauthorised gambling operators (DIAN).
- Stablecoin rails: Visa Direct moved stablecoin prefunding into production in October 2026. Mastercard and BVNK launched Global Money Platform on 15 October with Nuvei and Marqeta among launch users (CoinDesk).
What PSPs do for high-risk merchants
| Function | Description | Main risk |
|---|---|---|
| Acquiring access | Aggregates merchants under an acquirer relationship, as a payment facilitator or ISO | Acquirer exit; VIRP registration |
| Local payment methods | Bank transfers, wallets, vouchers and QR payments in each market | Local licensing and bans |
| Payouts | Withdrawals to players, clients and sellers, often through push-to-card or bank rails | Prefunding and liquidity |
| Orchestration | Routing across several processors for approval rates and resilience | Data and descriptor consistency |
| Settlement | Collecting funds and settling net to the merchant, often after a reserve | Safeguarding and insolvency |
Multi-PSP routing is now common. 15M reported that Midnite moved from direct payment-provider integrations in the UK and Ireland to BR-DGE as an orchestration layer.
Visa's entity types
Visa decides each transaction's role separately. The same company can be the merchant for some transactions and a facilitator for others.
| Entity | Visa test | Example in the MDSM |
|---|---|---|
| Merchant | Represents itself to the buyer as selling the goods or services | Franchise and department store examples |
| Payment facilitator | Deposits transactions or receives settlement for merchants, sells nothing itself | — |
| Marketplace | Handles payments for sellers on a platform that brings many buyers and sellers together | Online marketplace for sheep farmers |
| Ramp provider | Converts fiat to non-fiat currency or vice versa | Card-to-Bitcoin ramp |
| Digital wallet operator | Assigns accounts and enables payments across multiple distinct types of merchant | Stored-value and staged wallets |
Risk sits with the PSP too
Merchants often treat their PSP as the stable layer. Regulators increasingly see PSPs as the enforcement point:
| Market | Event | Source |
|---|---|---|
| Turkey | 15 payment and e-money licences revoked in 2026, by 15M's count of central bank decisions | 15M |
| Indonesia | Central bank warning on involvement in illegal gambling QR payments (Oct 2026) | 15M |
| Philippines | Two of three companies on PAGCOR's payment gateway register had not begun operations as of 17 Sep 2026; by 20 Oct the list had five, three marked not yet operating | 15M, PAGCOR |
| Kazakhstan | Banks apply updated screening rules from 16 Oct 2026 to payments linked to online casinos and unlicensed foreign bookmakers | 15M |
| Canada | After FINTRAC revoked Gulliver Pay Inc.'s registration on 1 May 2026, a provider relying on it stopped onboarding | Finzil |
| Brazil | Payment institutions barred from betting transactions from 25 Sep 2026 | MP 1.394 |
| Colombia | Financial entities and PSPs must not serve unauthorised operators | DIAN (Decree 0240) |
| Netherlands | 15M found a MiCA-licensed CASP in four casino iDEAL flows (6 Oct 2026) | 15M |
WarningA PSP serving players in markets where gambling is not licensed puts every merchant on its books at risk. Check that your PSP's licences and markets match your own.
Where stablecoins fit for PSPs
- Merchant settlement. Paying merchants in stablecoins on weekends and holidays, or across borders without correspondent banks.
- Prefunding payout networks. Topping up Visa Direct and similar networks outside banking hours. See Prefunding.
- Treasury between entities. Moving liquidity between group companies in different countries.
- Card issuing. Stablecoin-linked card programmes, now numbering more than 160 on Visa (The Block, September 2026). See Card networks and stablecoin settlement.
flowchart LR
M[Merchant collections in local methods] --> PSP[PSP collection accounts]
PSP --> L{Merchant's settlement preference}
L -- Fiat --> F[Bank wire, banking days]
L -- Stablecoin --> C[Convert via licensed provider]
C --> SW[Screened transfer to merchant's whitelisted wallet]
SW --> TR[Travel Rule data sent with transfer]
PSP --> VD[Prefund payout network in USDC]
VD --> PY[Push payouts to cards and accounts]NoteFor a PSP, adding stablecoin settlement is a compliance project as much as a technical one. It brings Travel Rule data, wallet screening, custody and licensing questions. See Travel Rule and Wallet screening.
Licensing by jurisdiction (selected)
| Jurisdiction | Typical licence for a PSP | Stablecoin add-on |
|---|---|---|
| EU | Payment institution or e-money institution (PSD2/EMD2) | MiCA CASP authorisation for crypto services |
| United Kingdom | FCA payment or e-money authorisation | FCA cryptoasset authorisation from 25 Oct 2027 (gateway open now) |
| United States | State money transmitter licences, FinCEN MSB | GENIUS Act regime for issuers; state crypto licences |
| Brazil | BCB payment institution authorisation | BCB virtual-asset service provider rules |
| Philippines | BSP operator of payment system registration; PAGCOR accreditation for gaming | BSP VASP rules |
Regimes are summarised for orientation only. Check the current position with local counsel.
Illustrative example: weekend settlement for a merchant
Illustrative example. Figures are invented.
A PSP collects R$ and MX$ for a portfolio of e-commerce merchants and settles them in US dollars. Its correspondent bank processes wires on business days. On a holiday weekend, three days of collections, about US$1.8m, wait. Two merchants have opted into USDC settlement through a licensed provider. Their US$600,000 share is paid on Saturday, after the PSP's treasury converts and screens it. The other merchants are paid on Tuesday by wire. The PSP reconciles both against the same merchant ledger.
Timeline
| Date | Event |
|---|---|
| 6 Apr 2023 | VIRP guide requires acquirers to register high-risk agents |
| 1 May 2026 | FINTRAC revokes Gulliver Pay registration |
| August 2026 | Mastercard acquires BVNK (CoinDesk) |
| 25 Sep 2026 | Brazil bars payment institutions from betting transactions |
| 15 Oct 2026 | Mastercard and BVNK launch Global Money Platform |
| October 2026 | Visa Direct stablecoin prefunding goes into production |
| 16 Oct 2026 | Kazakhstan bank screening rules updated |
Q/A
Is a PSP the same as an acquirer?
No. An acquirer is a scheme member bank or institution. Many PSPs work under an acquirer's licence as facilitators or agents.
Why do PSPs ask merchants so many questions?
Under VIRP the acquirer attests annually to Visa that each high-risk merchant has effective controls, and that duty flows down to its agents.
Can a PSP settle merchants in stablecoins without a crypto licence?
Often not. Converting and transferring crypto for clients is a regulated service in most major markets. Many PSPs partner with a licensed provider instead.
What should merchants check about their PSP?
Licences, markets served, acquiring partners, safeguarding arrangements, reserve terms and any history of regulatory action.
Do PSPs carry Travel Rule duties?
If they transfer crypto for clients as a VASP or CASP, yes. See Travel Rule.
Why use orchestration?
To route around declines and outages, and to switch processors without rebuilding integrations.
Sources
- Visa, Visa Merchant Data Standards Manual (October 2026): https://usa.visa.com/dam/VCOM/download/merchants/visa-merchant-data-standards-manual.pdf
- Visa, Visa Integrity Risk Program guide (6 April 2023): https://www.visa.cl/content/dam/VCOM/regional/lac/SPA/chile/Documents/visa-integrity-risk-program-chile.pdf
- 15M, payments and fintech news: https://15m.com/news/payments-fintech/
- Visa, Visa Direct stablecoin prefunding (October 2026): https://investor.visa.com/news/news-details/2026/Visa-Direct-Launches-Stablecoin-Powered-Money-Movement-as-Pilots-Move-to-Production/default.aspx
- CoinDesk, stablecoin payments jump 45% (18 October 2026): https://www.coindesk.com/business/2026/10/18/stablecoin-supply-stalls-but-payments-jump-45-as-visa-mastercard-and-stripe-connect-crypto-to-cash
- The Block, Visa settlement tops US$20bn run rate (8 September 2026): https://www.theblock.co/news/business/2026-09-08-visa-stablecoin-settlement-tops-20-billion-annualized-run-rate-up-more-than-15x-year-over-year-413749
- Equity Ledger (23 October 2026): https://www.equity-ledger.com/articles/crypto-payments-weekly-review-2026-10-23
- Finzil (18 October 2026): https://finzil.com/blog/igaming-payment-challenges
- PAGCOR, list of accredited support service providers: https://www.pagcor.ph/regulatory/pdf/App%20Kits/List-of-PAGCOR-Accredited-Support-Service-Providers.pdf
- Planalto, Medida Provisória 1.394: https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2026/mpv/mpv1394.htm
- DIAN, Legislative Decree 0240 of 12 March 2026: https://www.dian.gov.co/normatividad/Decretos/Decreto-0240-12032026.pdf
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