MASAK compliance in e-commerce, merchant and buyer risk

E-commerce intermediary service providers are obliged parties under Law No. 5549. The distinguishing feature of the sector is that money laundering manifests not in the transaction itself, but in the authenticity of the product, price, and parties: payment for a product that is never actually delivered is recorded as a regular sale.

Who does the guide target?

E-commerce intermediary service providers are obliged parties under Law No. 5549 on Prevention of Laundering Proceeds of Crime, and MASAK publishes a dedicated suspicious transaction report guide for this group.

The guide defines its scope around intermediary service providers, meaning platforms where third parties make sales. An e-commerce business selling its own products on its own website is not the direct target of this guide. However, most of the indicators listed in the guide point to risks that have equivalents in any e-commerce structure that accepts payments: merchant and buyer behavior, product and price discrepancies, and the use of fake cards.

Which indicators does the guide list?

Indicators on the payment side

T-020-2.31 lists transactions made using fake credit card information and the detection of fake products being purchased alongside these transactions. T-020-2.21 adds a buyer or merchant performing an unusually high number of return transactions.

Both show that fraud control and money laundering control look at the same data. The chargeback rate is read not just as a payment issue, but also as a money laundering indicator.

Buyer behavior

T-020-2.27 lists buyers making sudden and high-value purchases outside their normal shopping habits, T-020-2.25 lists an unreasonable number of customers purchasing the same product within specific timeframes outside of special circumstances like discounts or campaigns, and T-020-2.29 lists a high volume of purchase transactions occurring from a specific region in a short period without a reasonable explanation.

None of the three can be detected by looking at a single order: they require the buyer's history, collective behavior around the same product, and geographic concentration.

Product and price

T-020-2.20 lists the sale of prohibited or dangerous products, T-020-2.22 lists the offering of identical or similar products for sale far outside market prices, T-020-2.30 lists frequent and sudden price changes incompatible with market conditions, and T-020-2.23 lists encountering different, fake, or completely undelivered products instead of the ordered item.

All four demonstrate that the product catalog and price history constitute risk data. A monitoring structure that only looks at the payment flow will not detect any of them.

Merchant side

For a business selling in its own store, these indicators correspond to the supplier and distributor side; for a platform operating a marketplace, they apply directly to their merchant onboarding process.

Who is the real party?

The first eighteen types in the guide share the same common core as other sectoral guides: concealing the ultimate beneficial owner (UBO) (T-020-2.11), the third party directing the transaction not being a party to official documents (T-020-2.9), the lack of a logical commercial link between the parties (T-020-2.12), and complex, multi-jurisdictional structures (T-020-2.13).

What does the reporting form require?

Suspicious matters that do not contain monetary value are written in the description section of the form, not the suspicious transaction section. This means a case must also be able to carry non-monetary events.

A report can be based on a single transaction or on multiple transactions within a specific date range; in the case of multiple transactions, the total amount and date range are reported together.

How is the suspicion category selected?

When making a report, the suspicion is placed into one of the categories in MASAK's reference table, and each category is mapped to the relevant legal regulation. This means case management must operate with this taxonomy rather than its own free-form tags.

What is the threshold for reports with a suspension request?

The regulation based on Article 19/A of Law No. 5549, titled "Suspension of transactions", governs the suspension of transactions based on a report. The guide sets a clear threshold for this: rather than mere suspicion, there must be documents or serious indications supporting the suspicion that the assets subject to the transaction are related to money laundering or terrorist financing, and these must be submitted along with the justifications.

This threshold directly generates a system requirement: evidence must be attached to the case, the justification must be written, and the identity of the decision-maker must be recorded.

How does TruvaLI meet these requirements?

Reading payment and user behavior in the same place

Order, payment, return, and chargeback data are aggregated with the user's device, IP, and contact data in the same customer view. Email and IP scores calculated at onboarding become inputs for subsequent rules.

Product and price data as rule inputs

When product category, price history, and catalog data can be connected, T-020-2.22, T-020-2.30, and T-020-2.20 become rules. Prohibited product lists are set up as internal lists and integrated into the screening flow.

Relationship network

The relationship network between buyers and merchants is mapped through shared IP, device, contact information, and payment instruments. Types looking at collective behavior, such as T-020-2.25 and T-020-2.29, cannot be detected through individual order checks.

Case, evidence, and category

An alert turns into a case with an owner, duration, and evidence. The suspicion category is selected from MASAK's taxonomy, the evidence and decision justification are written to an immutable audit trail, and the four-eye approval is executed via maker/checker. The report draft is prepared from the same case data, and the signature remains within the institution.

Related flows: merchant onboarding, chargeback and payment fraud, marketplaces, ongoing monitoring, and regulatory reporting. The framework is on the MASAK obligations page, and relationship analysis is on the fraud detection page.

Source

MASAK, "Suspicious Transaction Report Guide for E-Commerce Intermediary Service Providers", version 1.0.

This page does not constitute legal interpretation; it conveys the indicators and procedures listed in the guide. Rules, thresholds, and actions are configured according to the institution's own risk policy and obligations.