Red Flags in Marketplace Payments
The marketplace payment red flags compliance teams look for.
The list
- New seller with a large first payout
- Payout wallet on or adjacent to the sanctions list
- Seller ownership triggering the 50% rule
- Buyer/seller jurisdiction mismatch
- Payments split to stay under thresholds
- Refunds routed to a different wallet than the original payment
Why marketplace flows get flagged
Marketplaces are payment hubs with high volume - the BitPay settlement showed the merchant-payment shape in enforcement. The four surfaces (onboarding, jurisdiction, payouts, refunds) each carry flags.
The control
Screen at onboarding and on every payout; flag the patterns above; fail closed; log every decision with list versions.