Introduction
- What it is: This MCC encompasses establishments that provide hotel and casino services under the same roof.
- Risk level: Medium — Due to the gambling component, there is inherent variability in transaction behavior.
- Acceptance difficulty: Medium — Some payment processors view these businesses as higher risk, leading to varied acceptance rates.
- Typical business models: casino resorts; gaming hotels; integrated luxury casinos; entertainment-focused lodging.
- For merchants: Expect moderate MDR rates; potential for higher reserves from processors; thorough approval processes may be required.
- What PSPs expect: Evidence of business legitimacy; a clear description of gaming and accommodation services; compliance with gaming regulations.
Payment Insights & Benchmarks
Merchants in this MCC should plan for higher payment friction compared to standard e-commerce. Acceptance often depends on method mix, fraud controls, and PSP risk appetite.
Payment methods
Cards: often filtered by geo and traffic source, leading to variable approval rates.
- E-wallets and A2A: important alternatives for deposits and withdrawals among users.
- Vouchers and prepaid cards: popular for ensuring customer privacy and reducing chargebacks.
- Crypto: gaining traction, but acceptance varies across payment service providers (PSPs) and is often scrutinized under AML regulations.
Authentication & security
Strong authentication measures (3DS, SCA) are typically enforced to secure transactions.
- These tools help mitigate unauthorized access but may not eliminate friendly fraud.
- Continuous fraud monitoring should focus on transaction velocity, device fingerprinting, and behavioral analytics to enhance risk management.
Benchmarks (indicative, not guaranteed)
MDR: generally higher than the standard e-commerce rate due to increased risk factors.
- Rolling reserves: commonly required in double digits as a protective measure.
- Settlement cycles: typically longer, averaging 7+ days, compared to standard practices.
- Chargeback ratios: likely to be significantly above average retail levels, reflecting industry-specific challenges.
- Card approval rates: generally lower, with better success rates observed for e-wallets and local A2A options.
Key metrics to monitor
Authorization rates segmented by geographic region, payment method, and provider.
- Analysis of decline reason codes, categorized by payment schemes.
- Chargeback and dispute trends, differentiated between fraudulent disputes and service-related issues.
- Monitoring of average ticket size and betting velocity to assess fraud risk effectively.
Risk & Compliance
Merchants under this MCC are closely scrutinized due to elevated financial and reputational risks. PSPs and acquirers typically apply stricter controls, expecting merchants to proactively address fraud, chargebacks, and AML/KYC compliance.
Chargebacks & fraud
High incidence of friendly fraud (“I didn’t authorize this transaction”), bonus abuse, and the use of stolen cards.
- Multi-accounting and rapid betting patterns frequently arise as abuse strategies.
- Mitigation tools include behavioral analytics, velocity checks, and deposit/withdrawal limits to monitor and respond to unusual activity.
AML/KYC expectations
Strong customer identity verification (IDV) is crucial, including sanctions and politically exposed persons (PEP) checks.
- Source-of-funds verification is essential for large transactions or suspicious behaviors.
- Manual review triggers may include large or frequent deposits, transactions via atypical payment routes, or usage of VPN/proxy services.
Operational red flags
White-label setups lacking clear ownership and transparency regarding operators can raise alarms.
- Traffic from restricted geographies or through unverified affiliates may suggest higher risk.
- Absence of responsible gaming controls, such as self-exclusion options and betting limits, is a notable gap.
- Failure to communicate clear refund or return policies to players can lead to compliance concerns.
Onboarding Checklist
Merchants under this MCC should prepare a complete onboarding package before approaching PSPs or acquirers. A well-structured submission improves approval chances and shortens review times.
Legal & corporate documents
company registration and incorporation documents
- disclosure of beneficial owners (UBO) and corporate structure
- valid licenses for the relevant business activities
- policies: Terms of Service, Privacy, AML/KYC, Refund Policy, Responsible Gaming (if applicable)
Financials & risk management
recent financial statements and cashflow forecasts
- liquidity or reserve model for payouts
- description of antifraud setup and monitoring tools
Product & marketing
demo access or screenshots of the live platform
- marketing plan and traffic source overview (affiliates, SEO, PPC)
- geographic targeting information
- KYC flow details, including IDV providers and thresholds
Technical integration & security
payment architecture overview with supported methods/providers
- description of SCA/3DS flows, retry logic, and tokenization
- PCI DSS compliance status and data storage policy
Operations
customer support coverage (languages, 24/7 if available)
- SLA for dispute handling and chargeback response
- deposit, bet, and payout limits; self-exclusion mechanisms
- internal process for chargeback investigation and documentation
Regulation & Licensing
Licensing and certification are critical for merchants in this MCC, as PSPs and acquirers will require proof of compliance before onboarding. Recognition of licenses depends heavily on the merchant’s jurisdiction and the markets they target.
Operator licenses
Nevada Gaming Control Board (NGCB) — essential for casinos operating in Nevada, where Sam's Town is located, recognized widely for effective regulation in gaming.
- New Jersey Division of Gaming Enforcement (NJDGE) — required for operations in New Jersey, establishing rigorous standards and guidelines.
- Belgian Gaming Commission — oversees compliance for operators in Belgium, recognized in the EU for its stringent requirements.
- British Gambling Commission (UKGC) — necessary for operators targeting UK customers, ensuring a strong regulatory framework.
- Curaçao eGaming license — popular for online gaming platforms, though acceptance varies by PSP.
Geo-restrictions
States in the US with no legal framework for casino operations → transactions may be blocked or PSPs refuse onboarding.
- International markets may have varying restrictions on gambling operations, impacting the legality of certain transactions.
- PSPs may limit services to jurisdictions where the operator holds a valid gaming license.
Certifications & audits
PCI DSS compliance required for handling payment card information securely.
- RNG (Random Number Generator) audits to ensure fairness in gaming outcomes.
- Regular AML/KYC reviews and reports are typically mandated to combat money laundering and fraud risks.
- Responsible Gaming policy audits must be conducted to promote safe gaming practices.
Official Definitions & Network Comparisons
This section shows how major card networks define this MCC and highlights practical differences that affect merchant onboarding.
| Network | Definition | Key notes |
|---|---|---|
| Visa | Gambling transactions, including casino and online bets | Requires recognized license; geographic and product restrictions; subject to special MCC screening |
| Mastercard | Casino-related transactions and internet gambling | High transaction monitoring; additional requirements for online gambling operators |
| American Exp. | Gambling-related services including casinos | Stricter underwriting criteria; potential for higher fees for high-risk categories |
| Discover | Transactions for gambling, casino, and related establishments | Specific limits on transaction amounts; varies by region |
Explanation:
Although the definitions across networks seem similar, the terminology—such as "gambling," "casino," and "online betting"—can lead to different interpretations. Networks may require separate merchant IDs for distinct products or locations. Common reasons for denial include the absence of a valid gambling license, operation in high-risk areas, and lack of transparency regarding traffic sources.
Alternative MCC Codes
Merchants often confuse this MCC with other categories. The table below shows which codes are related, why they are confused, and what risks misclassification brings.
| MCC | How it is used | Why confused | When acceptable | What is risky |
|---|---|---|---|---|
| 7995 | Gambling | “We offer gambling services” | Legitimate gambling establishments | Misclassifying daily operations as mere entertainment |
| 7011 | Hotels and motels | “We provide lodging” | Hotels with casino facilities | Hotels without gambling attempting to classify as casinos |
| 7993 | Bowling alleys and game facilities | “We have gaming options” | Bowling alleys with recreational games | Misclassifying gambling-related facilities as entertainment |
| 5813 | Bars and cocktail lounges | “We serve alcohol in our entertainment” | Establishments hosting live entertainment with a bar present | Any form of gambling being framed as a social event |
Rule of thumb for merchants:
If your business prominently features gambling activities, it should be classified under MCC 3564. Using an alternative code aiming to avoid scrutiny can lead to severe compliance issues and a potential loss of your merchant account.
Best Practices for Merchants
Merchants operating within the MCC of 3564 (SAM'S TOWN HOTEL AND CASINO) must navigate a complex set of challenges regarding payment processing, risk management, and operational compliance. Adhering to the practices outlined below can help enhance transaction acceptance, minimize disputes, and foster robust partnerships with payment service providers.
Classification & transparency
always use the correct MCC to ensure proper classification; misclassifications can lead to account termination
- provide clear information regarding gaming licenses, operational jurisdictions, and responsible gaming policies on your website
- maintain transparent business practices and ensure clear communication through billing descriptors to avoid confusion
Fraud & chargeback reduction
implement 3D Secure (3DS) or step-up authentication measures, particularly for high-risk transactions based on amount, geographic location, and device type
- ensure billing descriptors are clear and recognizable to customers, coupled with prompt confirmation notifications via SMS or email
- systematically log transaction and gaming events to build a comprehensive evidential base for dispute representments
Payment acceptance optimization
offer multiple payment methods, including credit cards, e-wallets, and local payment options, to reduce reliance on any single method
- actively route payment traffic based on geographical locations, banking partnerships, or payment method effectiveness, and conduct A/B testing on PSPs
- consider utilizing separate merchant IDs (MIDs) for different products or services to optimize compliance with varying scheme requirements
Operational discipline
regularly monitor key performance indicators (KPIs) such as authorization rates, decline codes, chargeback ratios, and customer lifetime value (LTV)
- perform compliance audits and reviews of internal policies continuously, running periodic test transactions to ensure operational integrity
- designate a team member to manage disputes, ensuring a response strategy aligned with service level agreements (SLAs)
Payouts & liquidity
establish liquidity buffers to accommodate rolling reserves and any potential delays in settlements
- automate anti-money laundering (AML) checks on withdrawals, especially for transactions that surpass established thresholds
- keep a close watch on payout speeds and detect any irregular withdrawal patterns to proactively manage risk
Business Scope & Examples
This MCC covers businesses that primarily operate in the casino sector, including those that offer games of chance and various gambling activities. Merchants classified under this category typically provide environments where customers can wager real money on games such as slots, table games, and other gambling-related offerings. The focus is on establishments with physical or virtual real-money gaming operations.
Models
casino operations (slots, roulette, table games)
- sportsbook platforms (pre-match and live betting)
- online poker rooms and tournaments
- lotteries and bingo services
- fantasy sports platforms
Borderline cases
Skill gaming — real-money competitions based primarily on player skill (e.g., chess, esports); often requires separate review.
- Esports betting — wagering on esports matches; usually treated as part of this MCC.
- Social casino — apps with virtual chips that can be monetized; sometimes considered gambling if real-value exchange exists.
Signals for correct classification
customer deposits real money to participate in games
- platform operates with a house edge or bookmaker margin
- rules set limits for wagers, winnings, and responsible play
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