Do you “consciously avoid knowing” that your merchant is engaging in unlawful practices? Are you providing a merchant with processing services without which it would be impossible for a scammer to charge consumers?
Federal Regulations have long noted the importance of proper initial due diligence in boarding merchant accounts. http://www.fdic.gov/regulations/examinations/supervisory/insights/sisum11/managing.html.
How would you as an ISO or processor react if your name and company were substituted for the defendants in this recent FTC filing?
You might want to take time and read the allegations.
In retrospect would it have been worth spending $75.00 or so with us to get a full background report on principal and business, as well as an on-site visit with photos and copies of scripts, licenses and other appropriate documents?
Would initial proper due diligence on known high risk merchants mitigate the wrath of some subsequent FTC inquiry?