In plain English: this Risk Policy tells you when Veyra can place a hold on your transactions, set or raise a reserve, delay your payouts, or restrict access. The answer is: we can do any of these at any time, for any reason we judge sufficient. The list of triggers below is not exhaustive; it is illustrative.
This Risk, Holds & Reserve Policy (the “RISK POLICY”) describes when and how Veyra may place transactions on hold, hold reserves, delay payouts, claw back settled funds, or restrict access to the platform. It supplements the Merchant Services Agreement and the Payment Processing Terms. By processing payments on Veyra, you agree that Veyra may take any action described below at any time and in our sole reasonable discretion, with the minimum notice consistent with applicable law.
1. CONTINUOUS RISK MONITORING
Veyra operates continuous, automated risk monitoring across every merchant on the platform. Monitoring includes — but is not limited to — analysis of authorization ratios, decline reasons, dispute rates, refund rates, chargeback reasons, velocity, ticket size, geographic distribution, customer complaints, BIN-level signals, device and network fingerprints, cross-merchant abuse signals, payment-method anomalies, domain-content scans, sales-channel changes, statement-descriptor consistency, beneficial-ownership changes, sanctions screening, regulator referrals, operator referrals, and partner-bank intel.
2. MANUAL REVIEWS
Any merchant, transaction, beneficial owner, or principal officer may be selected for manual review at any time. Reviews may be triggered by automated signals, by an operator, by an acquiring partner, by a card network, by a sponsor bank, by a regulator, by a law-enforcement authority, or by a customer complaint. Reviews may result in additional document requests, settlement delays, reserve adjustments, restrictions on processing, or termination. You agree to cooperate with reasonable review requests within commercially reasonable timeframes and at your own cost.
3. TRANSACTION HOLDS
Veyra may hold or delay capture, settlement, or payout of any individual transaction pending review or risk decisioning. Held transactions may be voided, refunded, claw-backed, or released depending on the outcome of review. Veyrahas no obligation to advance the funds underlying a held transaction.
4. MERCHANT-LEVEL HOLDS
Veyra may place a merchant-level hold suspending some or all processing, settlement, or payouts for the affected merchant. Triggers include but are not limited to:
4.1. elevated chargeback or refund rates, whether published or operator-set;
4.2. sudden changes in transaction volume, ticket size, geography, payment-instrument mix, or product category;
4.3. regulatory inquiry, examination, subpoena, or governmental investigation;
4.4. sanctions, OFAC, or adverse-media hit on the merchant, beneficial owners, principal officers, or counterparties;
4.5. customer complaints suggesting deceptive practice, defective goods, failure to ship, or unauthorized billing;
4.6. mismatched, unverified, expired, or stale business information or beneficial-ownership records;
4.7. card-network or acquirer direction, including notice of program enrollment (Visa VDMP / VFMP / Mastercard ECM / VAMP / etc.);
4.8. identification of prohibited goods or services or Acceptable Use Policy violations;
4.9. suspected card testing, account testing, transaction laundering, or other abuse;
4.10. suspected money-laundering, structuring, terrorist-financing, or sanctions-evasion activity;
4.11. fraud, identity-theft, or stolen-instrument indicators;
4.12. domain takedown, expiration, or unauthorized change;
4.13. unauthorized embed deployment or HMAC signing-key compromise;
4.14. change in beneficial ownership, control persons, principal officers, or capital structure;
4.15. insolvency event, bankruptcy filing, assignment for the benefit of creditors, or similar proceeding;
4.16. partner-bank request or acquirer request;
4.17. any other circumstance creating risk to Veyra, our partners, consumers, or the integrity of the payments system.
5. RESERVES AND ROLLING RESERVES
5.1. UNILATERAL IMPOSITION AND ADJUSTMENT.We may establish, increase, decrease, or release reserves at any time, with no more than thirty (30) seconds' constructive notice (delivered as a system event in your dashboard, an email to your administrative contact, or a webhook). Reserves may be implemented as a fixed amount, a percentage of processing volume, a rolling reserve over any window we set, or any combination.
5.2. PURPOSE. Reserves are intended to cover anticipated chargebacks, refunds, fees, fines, integrity assessments, indemnities, and other amounts that may become due to Veyra, our acquiring partners, or our processors. Reserves do not accrue interest in your favor unless required by applicable law.
5.3. RELEASE STANDARD. Reserves are released at the LATER of (a) a continuous chargeback-free window of at least one hundred eighty (180) days from the most recent transaction, AND (b) the completion of every open dispute, investigation, regulatory inquiry, or audit matter associated with your account. Reserves may be retained beyond termination for the longer of one hundred eighty (180) days, the close of every open matter, or such longer period as is required by card-network rules, applicable law, or partner-bank direction. See also the Merchant Services Agreement §7.3 and §7.4 (Conversion to Permanent Loss Reserve).
5.4. FUNDING. Reserves may be funded by withholding from settlement, by debiting your designated bank account under the standing ACH Authorization without any additional authorization, or both.
6. DELAYED AND MODIFIED PAYOUTS
Settlement and payout schedules are not guaranteed. Veyra may delay or modify payouts, including by lengthening the settlement window, switching the payout currency, switching the recipient account, splitting payouts between settlement and reserve, or pausing payouts entirely. We are not responsible for delays caused by your bank, the originating depository institution, the network, sanctions screening, or any partner.
7. INFORMATION AND DOCUMENT REQUESTS
We may request — and you agree to provide on demand and at your sole cost — documents and information including:
7.1. processor statements, prior-merchant statements, or volume reports;
7.2. bank statements for the operating or settlement account;
7.3. customer-service recordings, transcripts, or ticket logs;
7.4. refund and dispute records;
7.5. vendor and fulfillment agreements;
7.6. shipping or delivery records;
7.7. identity verification of beneficial owners and control persons;
7.8. website screenshots, marketing artifacts, and ad copy;
7.9. license, registration, or permit documentation;
7.10. financial statements, tax returns, and bank reconciliations;
7.11. supplier and manufacturer agreements;
7.12. customer order forms, receipts, and signed terms;
7.13. any other information reasonably required to assess risk or compliance.
Failure to provide any requested item within the deadline Veyra sets — or provision of false or misleading information — is grounds for immediate suspension, increased reserve, termination, and indemnity.
8. OFFSET, RECOVERY, AND DEFICIENCY
You authorize Veyra(and our acquiring partners and processors) to debit, offset, net, or recover from your settlement, reserve, or bank account any amount owed under the Merchant Services Agreement. To the extent any offset is insufficient, you remain liable for the deficiency and will pay it on demand, together with any reasonable collection costs, attorneys' fees, and interest at the lesser of (a) one and one-half percent (1.5%) per month or (b) the maximum rate permitted by applicable law. Offset rights survive termination indefinitely.
9. SUSPENSION AND TERMINATION FOR RISK
Veyra may at any time suspend, throttle, or terminate processing for risk, compliance, or operational reasons. Suspension and termination decisions are not appealable to a court for de novo review of the underlying risk analysis; Veyra retains sole discretion over risk decisioning. We will consider operator-submitted clarification information where time and circumstances permit, and where doing so does not increase risk to Veyra, our partners, or consumers; we are under no obligation to consult, hear from you, or wait before suspending or terminating.
10. COOPERATION AND CONFIDENTIALITY OF RISK METHODS
You will cooperate with reasonable risk requests and will keep confidential any specific risk thresholds, model weights, detection mechanisms, alerting signals, decisioning logic, or operator communications shared with you under this Agreement. Information about Veyra's risk decisioning is not a representation about a particular outcome and may change at any time. You will not seek discovery of risk-model internals in any proceeding except as ordered by a court of competent jurisdiction under a confidentiality regime acceptable to Veyra.
11. NO LEGAL ADVICE AND NO GUARANTEE
Nothing in this Risk Policy is legal, financial, regulatory, or compliance advice, and nothing in this Risk Policy entitles you to a specific risk decision. Veyrareserves all rights with respect to risk decisioning consistent with the Merchant Services Agreement and the Terms of Service.
12. SURVIVAL
§5 (Reserves), §7 (Records), §8 (Offset and Recovery), §10 (Confidentiality of Methods) survive termination of this Agreement indefinitely, subject only to the Merchant Services Agreement §19.
13. CONTACT
Questions about this Risk Policy or about a specific hold or reserve action on your account:
Josh Petro LLC
risk@veyragate.com
Version 2026.05.23. Effective 2026-05-23.