What happens when a NoRamp RUO merchant crosses the line
We do not issue warnings for prohibited conduct. This page describes, step by step, what happens when our nightly scans or a human reviewer finds a Research Use Only merchant selling a prescription compound, marketing for human use, selling to individuals, or doing anything else on our prohibited-conduct list.
Detection
Every live merchant storefront in this category is scanned nightly. The scan reads the HTML the server actually sends for every public page on every connected domain and looks for prescription compounds under any name or code, human-use language, consumer formats, injection supplies, clinic framing and disclaimers that exist only for the crawler. Order patterns and marketing channels are reviewed on an ongoing basis. Human reviewers confirm what the scans find, and we investigate every report we receive from the public, from other merchants and from our partners.
Same-day suspension and termination
Processing stops the moment a violation is confirmed. There is no cure period for conduct on the prohibited list and no second chance. Terminated merchants are not reinstated, are not re-boarded under a new name or entity, and are not referred to another processor.
Funds are held
Settled and unsettled funds are held for as long as the card networks permit, up to 180 days, to cover refunds, chargebacks, assessments and investigation costs. Reserves are retained for the same purpose. The merchant agreement grants NoRamp a security interest in processed funds for exactly this situation.
Every fine passes through, in full
Any fine, assessment, penalty or fee levied by a card network, acquiring bank or processor because of a merchant's conduct is the merchant's to pay. Mastercard's Business Risk Assessment and Mitigation program and Visa's Integrity Risk Program assess fines that routinely reach tens of thousands of dollars per violation and can reach hundreds of thousands. We recover those amounts, plus our investigation and legal costs, from held funds and reserves, and we pursue any balance from the merchant and its principals under the merchant agreement.
This is not a negotiating position
It is what the networks and our banking partners require of us, and it is what we would do regardless. A merchant who crosses the line is not paying a NoRamp penalty. They are paying the real cost of what they did.
We report
We cooperate fully with our processor, our acquiring banks and the card networks, including identifying the merchant and its principals for network termination lists such as Mastercard's MATCH list. Where a violation involves products sold for human use, we cooperate with the FDA, the FTC and state regulators. We do not shield a merchant from a regulator, and we do not tip a merchant off.
What is not treated this way
Incidental presentation issues that are not on the prohibited list, for example an outdated page that is missing the research-use notice, are raised with the merchant and must be corrected by a stated deadline. The distinction is between a mistake and a business model. We can tell the difference, and so can the networks.
Frequently asked
Does NoRamp warn a merchant before terminating for RUO violations?
No. Conduct on the prohibited list results in same-day suspension and termination with no cure period. Only incidental presentation issues that are not on the list are raised with a deadline.
Who pays card-network fines for an RUO violation on NoRamp?
The merchant, in full, plus NoRamp's investigation and legal costs. Fines are recovered from held funds and reserves, and any balance is pursued from the merchant and its principals under the merchant agreement.
Where we stand
NoRamp is the strictest payment processor in the world for Research Use Only. We are on the side of the card networks, the acquiring banks and the regulators, not on the side of a merchant who wants to see how close to the line they can operate. Approval is possible. It is rare, on purpose.