How to deal with being MATCH listed (whitehat business)

pebble

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Dec 28, 2022
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Hello everybody,

I'm currently facing an issue with payment processing for my whitehat ecommerce businesses, as my main company has been MATCH/TMF listed.

Thus, I'm looking for insights from someone who has been in the same situation and fixed it.

To describe the situation, we had an issue with a bad batch of stock which resulted in a high amount of CBs, which landed my main company (lets call it Company 1) on a TMF list.

I found out after I tried making an additional stripe account for Company 1 after this, and they instantly rejected me with the reason being that me or my company is on a MATCH list.

In the meanwhile, I managed to get Company 1 set up with a new processor, but I believe this is most likely due to our application being approved before Company 1 got registered on the TMF list

Thanks to this we've fixed most of our processing needs for the latest year, but because of new projects being launched, we need a sustainable setup for the long haul.

I also launched a UK company (lets call it Company 2), for some minor projects, and we actually managed to process a bunch through this (just paying funds into Company 1's bank account) with no issues, we even passed a Stripe manual/routine review (asking for supplier invoices, photos of stock etc.)

What I took away from the above is that maybe Company 1 is MATCH/TMF listed, but maybe my identity as director is not.

Therefore I created a new company (lets call it Company 3) which is incorporated in the same European country as Company 1, on the same virtual office address, with only me being a director in it.

Stripe application for Company 3 went smoothly, but after we processed a few hundred thousand euros, we got a manual/routine review from stripe where they requested articles of incorporation, supplier invoices, tracking numbers and so on.

30 minutes after submitting the above for Company 3, I received an email that our processing account has been closed, not due to anything with MATCH/TMF list, but because the account has too much risk (no chargebacks or anything, completely white hat business with stock in Europe).

Thus I believe this must have something to do with my identity being “tainted” by still being director in a MATCH/TMF listed corporation.

My main objectives are the following:
  • Get back to processing as soon as possible, as we have stock that needs to be sold, and competitors who are eager to undertake us.
  • Get a sustainable setup where we don't have to stress about the MATCH/TMF issues, so we can focus on doing bigger volume in our business

The solutions I have are these:
  • Script for cloaking stripe payments (or any other processors)
  • 2 Identities of family members I can use the set up a new Stripe acc and get back up asap
  • The same 2 identities can be used for incorporating a new company and getting a more sustainable solution for the long haul.

My idea is to first set up a UK company in a family members name, use cloaked stripe payments, and pay the funds into company 1's bank account (Company 1 will obviously not be holding the UK company).

Then, just to see if whether Company 3 is also MATCH/TMF listed or if my identity is (already spent a few thousands setting it up), I will send out applications to normal ecom processors, and start doing bigger volumes.

What do you guys think of this solution, and do you reckon it can land me or my family in trouble if we use a UK company solely for processing and pay funds into Company 1's bank accounts?

If anyone has been in a similar situation im happy to pay to go on a call of for a detailed write-up, to learn how you handled it.
 
In some cases, you can go back to the processor that put you on the lists and ask them what you can do for them to remove you. Otherwise, it's a five year waiting period.

The only people who know what details are MATCH/TMF listed are the processors. Sometimes it's just the URL and company name, sometimes it includes names of directors and shareholders. If you want to be safe, assume everything is tainted.

Be careful about crossing the streams of money. Make sure your CFO/accountant knows what you're doing and that you can hold up if audited.

As for using family members, that will work provided they aren't also listed. Checks are rarely thorough enough to match people just by surname. If it's a new person, new company, new URL, and no other connection to Company 1, it'll probably not be noticed.

It's not often checked but would be easy to detect that Company 1 receiving payments for both Company 2 and Company 3, in which case Company 2 and Company 3 would risk account closure and delayed settlements. It would be better if Company 2 and 3 have their own bank accounts.

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This is the probably the answer to your question.
 
Sols said:
It's not often checked but would be easy to detect that Company 1 receiving payments for both Company 2 and Company 3, in which case Company 2 and Company 3 would risk account closure and delayed settlements. It would be better if Company 2 and 3 have their own bank accounts.
Click to expand...
Hey Sols,

Thank you for the reply.

How can processors check that Company 1 receives payments from a new company, if i set a new bank account for the new processing account (Company 1 has a payoneer account where i can set up multiple euro accounts for example)?

The reason I'd wanna go with this route, is to avoid complications with VAT, accounting and so on.
 
pebble said:
How can processors check that Company 1 receives payments from a new company, if i set a new bank account for the new processing account (Company 1 has a payoneer account where i can set up multiple euro accounts for example)?
Click to expand...
Maybe I missed a detail in your post, but if you are instructing Stripe to send money for payments processed by Company 2 to a bank account that belongs to Company 1, that's something they can detect.

My idea is to first set up a UK company in a family members name, use cloaked stripe payments, and pay the funds into company 1's bank account (Company 1 will obviously not be holding the UK company).
Click to expand...

That sounds like you're having Stripe settle funds to Company 1. But if Stripe settles to Company 2 and Company 2 later passes the funds on to Company 1, that part shouldn't be a problem.

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This is the probably the answer to your question.
 
Since you're a US person:

S or C Corp: the company pays tax and shareholders pay tax on dividends. Salaries are taxed as salaries.

LLC: the company's profits become personal income for the member/s, who must pay income tax accordingly.

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This is the probably the answer to your question.
 

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