Visa’s new Visa Acquirer Monitoring Program (VAMP) is shaking up the payments space, and for high-risk merchants, the stakes are higher than ever. VAMP was designed to crack down on excessive fraud, chargebacks, and suspicious activity across the Visa network. While the program’s goal is to protect consumers and the integrity of the payments ecosystem, it places high-risk merchants directly in the crosshairs.
Why VAMP is Bad News for High-Risk Merchants
Merchants in high-risk industries — whether it’s subscription services, nutraceuticals, travel, or credit repair — are already flagged for higher levels of fraud, disputes, and regulatory scrutiny. Under VAMP, acquiring banks face steep fines and penalties if their merchants generate too many fraud alerts or exceed ratio thresholds. The unfortunate reality is that even legitimate high-risk businesses can fall into these categories due to:
- Limited fraud prevention tools compared to mainstream retailers
- Repeat or recurring transactions that customers sometimes forget or dispute
- Data collection challenges, where gaps in customer information make it harder to authenticate buyers
When these issues pile up, the result is often account closures, funding holds, or heavy fines from acquiring banks eager to avoid Visa’s penalties.
CE 3.0: The Key to Preventing Fraud Alerts and Closures
This is where Compelling Evidence 3.0 (CE 3.0) comes in. CE 3.0 is Visa’s framework for resolving disputes and identifying legitimate transactions. Importantly, it’s also the only method to suppress TC40 fraud alerts (the reports Visa uses to track fraud across merchants and acquirers). By supplying the right data under CE 3.0, merchants can prove that a disputed charge was valid and keep fraud ratios under control.
For high-risk merchants, keeping fraud ratios under control is critical. Without CE 3.0 in place, TC40 alerts can snowball quickly, triggering VAMP thresholds and ultimately leading to merchant account termination.
How PayKings Helps Merchants Stay Compliant
The changes Visa is making are to incentivize merchants and acquiring banks to utilize fraud prevention tools. At PayKings we help merchants set up fraud prevention tools and provide reliable high risk merchant accounts with top-notch acquiring banks. Our team helps businesses:
- Get set up with fraud tools that meet Visa’s CE 3.0 requirements
- Ensure their merchant accounts remain compliant under VAMP
- Implement data collection and dispute management strategies that reduce risk
PayKings is here to help you protect your business, stay compliant, and secure the payment processing you need to grow. Sign up for PayKings today for a secure, reliable, and long-term high-risk merchant account that won’t collapse at the first sign of trouble.
Frequently Asked Questions
- VisaNet card-not-present transactions
- Domestic transactions
- Cross-border transactions
- Code 10 fraud disputes
- Non-fraud codes 11, 12, and 13 transactions
Compelling Evidence 3.0 is Visa’s updated standard for fighting fraud-related chargebacks, launched in 2023. It gives merchants a stronger way to prove that a disputed transaction was legitimate and authorized by the cardholder.
Under CE 3.0, merchants can present consistent data from at least two previous transactions made by the same customer using the same payment credentials (such as device ID, IP address, or account login). If this evidence matches the disputed transaction, Visa allows the merchant to deflect the chargeback before it escalates.
If your business has 1500 or more disputes a month Visa may enroll you in the VAMP program. This is of course considered against the total amount of transactions being processed for your business.
If you have 1500 or more disputes a month and have a 0.5% - 0.7% dispute rate the acquirer will be charged a 4$ fee for each transaction above that threshold. If the dispute rate is above 0.7% the acquirer will be charged $8 for each dispute. This cost is usually passed along from the acquiring banks to the merchants.
The number of enumerated transactions divided by the total number of transactions.
If 20% or more of a merchant’s transactions are enumeration transactions (and they have over 300,000 such transactions) the merchant will be enrolled in VAMP and incur penalties.
The Visa Dispute Monitoring Program (VDMP) was a program that focused on merchants with excessive chargebacks. If a business exceeds Visa’s chargeback thresholds, they’re placed in VDMP, which can lead to fines, stricter monitoring, and even account termination if the issue isn’t resolved. VDMP was replaced by VAMP on April 1, 2025.
Visa’s Fraud Monitoring Program (VFMP) was a program used to keep track of fraud-to-sales ratios using TC40 data (fraud reports submitted by issuers). Merchants that were flagged under VFMP were businesses with high levels of confirmed fraud. If ratios were above Visa’s thresholds, the acquiring bank and the merchant would both face penalties, and could result in the merchant account being shut down.
Visa is combining VDMP and VFMP into VAMP. Instead of using old indicators Visa is now using their new VAMP ratio to evaluate businesses. The VAMP ratio is calculated by dividing total disputes (both legitimate and fraud-based) by the total number of sales. If a merchant’s VAMP ratio is too high, merchants will be placed in the VAMP program, which costs merchants additional fees and penalties.
Enumeration transactions are small transactions that criminals use to test credit card information to find valid payment details so they can then use the cards for fraudulent purchases. The transactions are often a dollar or lower. Credit card companies hold merchants responsible if their payment system is being used for enumeration.
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Kyle Hall is a fintech entrepreneur, software engineer, and marketing strategist with over a decade of experience in high-risk payment processing and SaaS development. He is the CEO of PayKings, a lea...
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