Description

A focused course, tailored for you

The Payments Acquirer General Counsel Operating Manual

How an Assistant General Counsel at a global card acquirer runs network attestations, regulator inquiries, merchant indemnity disputes, and sanctions sign-off as one disciplined function.

A network rules attestation, a regulator data request, a chargeback litigation memo, and a sanctions exception request all hit the AGC desk in the same week. They are four different legal disciplines, and they all converge on one signatory.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

Assistant General Counsel roles at card acquirers and processors carry an unusual load. The function sits between scheme rules that change quarterly, prudential regulators that ask different questions in different jurisdictions, merchant contracts that allocate billions in indemnity exposure, and an operations floor that needs sanctions and AML sign-off on a 24-hour clock. Most acquirer legal teams handle these as separate workstreams, which produces duplication on the small matters and gaps on the consequential ones. The artefacts that decide whether the function is run as one discipline or four are concrete. A network rules attestation log with named signatories per scheme and version. A regulator inquiry response template that distinguishes CFPB from OCC from FCA from EBA from RBI. A merchant indemnity playbook that names the clauses, the carve-outs, and the standard counter-positions. A sanctions and OFAC escalation matrix that operations, legal, and the BSA officer all reference from the same document. A scheme litigation tracker that the board can absorb in two minutes. Building those artefacts, in sequence, is the work. This course is the operating manual.

What you walk away with

Run a quarterly network rules attestation cycle across Visa, Mastercard, Discover, Amex, and the domestic schemes with a documented signatory log per rule version.
Respond to a CFPB, OCC, FCA, EBA, or RBI inquiry with a jurisdiction-specific template that preserves privilege, scopes the data ask, and lands the response inside the regulator's clock.
Defend a merchant breach indemnity, fraud loss, or BIN sponsorship claim with a worked playbook of clauses, counter-positions, and settlement ranges.
Stand up a sanctions and OFAC escalation matrix that operations, legal, and the BSA officer reference from the same artefact and that survives a regulator examination.
Build a scheme litigation and rulemaking tracker that the board can read in two minutes and that surfaces interchange, antitrust, and operating regulation exposures before they become headlines.

The 12 modules

Module 1. The Acquirer Legal Function as One Discipline

Maps the AGC seat at a card acquirer against the four workstreams that collide on it: network rules, regulatory inquiries, merchant commercial disputes, and sanctions sign-off. Walks through the org chart relationships with compliance, risk, network relations, and the BSA officer, and names the artefacts that make the function legible to the GC, the board, and the schemes. Sets the operating cadence the rest of the course builds against.

Module 2. Network Rules Attestation Cycle

Builds the quarterly attestation log for Visa Acquirer Risk Standards, Mastercard Security Rules and Procedures, Discover, Amex OptBlue, and the domestic schemes. Names the rule families that change most often, the signatory chain inside the acquirer, the evidence each scheme actually asks for on inspection, and the failure modes when a rule version slips past a deadline. Includes a worked attestation log template with named columns for rule, version, signatory, evidence reference, and next review date.

Module 3. Regulator Inquiry Response Templates by Jurisdiction

Compares how the CFPB, OCC, FCA, EBA, and RBI actually structure a data request to an acquirer or processor, with the recurring sub-asks each one uses. Builds five jurisdiction-specific response shells that preserve privilege, scope the data ask narrowly, and land inside the regulator's clock. Names the moments when outside counsel is required and when in-house signature is sufficient. Includes a worked inquiry-tracking spreadsheet that the GC can review weekly.

Module 4. Merchant Agreement Indemnity Playbook

Walks the standard merchant agreement clause stack a card acquirer relies on: indemnity, limitation of liability, chargeback liability allocation, breach notification, reps and warranties, and termination for cause. For each clause, names the standard acquirer position, the standard merchant push-back, the carve-outs that get conceded, and the ones that cannot. Includes a worked redline of a contested merchant agreement with annotated counter-positions.

Module 5. Sanctions, OFAC, and Sanctions-Adjacent Escalation

Builds the escalation matrix that runs from a screening hit on the operations floor to a 24-hour legal review to a BSA officer sign-off and, where required, an OFAC voluntary disclosure. Distinguishes US OFAC from UK OFSI from EU consolidated lists from regional sanctions programs that the acquirer's merchant book actually touches. Names the artefact every regulator examiner will ask to see, and the trap of treating sanctions as a compliance-only matter.

Module 6. Chargeback, Fraud Loss, and Dispute Litigation

Distinguishes the scheme arbitration path from the civil litigation path for a contested chargeback or fraud loss. Walks through the standard merchant claim categories: undisclosed fees, fraud loss allocation, breach-related indemnity, and BIN sponsorship termination. Names the deposition preparation choices that an AGC actually makes on these cases, and the settlement range patterns that emerge by merchant category. Includes a worked dispute tracker by claim type and stage.

Module 7. BIN Sponsorship and Payment Facilitator Risk Allocation

Walks the legal architecture of a BIN sponsorship relationship and a payment facilitator program from the AGC seat. Names the standard liability allocation across acquirer, sponsor bank, payfac, and submerchant, and the clauses that have been litigated. Surfaces the recurring failure modes: undercapitalized payfacs, sub-merchant onboarding gaps, and chargeback indemnity that does not flow to the right party. Includes a worked BIN sponsorship agreement annotated by risk allocation point.

Module 8. Money Transmission, E-Money, and Licensing

Walks the US state-by-state money transmission licensing footprint, the UK Electronic Money Institution permission, the EU PSD2 payment institution authorisation, the Australian AFSL and APRA-relevant designations, and the regional licensing the acquirer's book actually touches. Names the artefacts each regulator examines on a renewal or change-of-control filing. Includes a worked licensing register the GC can present to a prudential examiner.

Module 9. Privacy, Data Localisation, and Cross-Border Payment Data

Treats privacy as the AGC sees it: a function of where cardholder data sits, where it moves, and which regulator gets to ask about it. Walks GDPR, UK GDPR, CCPA and the US state stack, India DPDP, Brazil LGPD, and the data localisation rules in jurisdictions that materially constrain acquirer architecture. Names the contractual data processing position the acquirer takes with its merchant book, and the standard sub-processor allocation. Includes a worked data flow map for a representative acquirer footprint.

Module 10. Scheme Litigation, Rulemaking, and Interchange Exposure

Builds the tracker that lets the board read scheme-level exposure in two minutes. Names the categories: ongoing interchange litigation, antitrust action against the schemes, operating regulation changes with attestation deadlines, and rulemaking proceedings at the CFPB, OCC, FCA, EBA, and RBI that materially affect acquirer economics. Names the moments when the acquirer files its own comment, joins an industry comment, or remains silent.

Module 11. M&A, Change of Control, and Regulator Notice

Walks the legal workstream when the acquirer buys a portfolio, sells a vertical book, or undergoes a change of control. Names the regulator notice obligations across state money transmitters, the OCC, the FCA, the EBA, RBI, and the schemes, and the sequence in which each consent is sought. Surfaces the failure mode where a deal closes ahead of a required notice. Includes a worked change-of-control checklist by jurisdiction and counterparty.

Module 12. Board, Audit Committee, and GC Reporting

Builds the AGC's standing report to the GC, the audit committee, and the board. Names the four numbers and four artefacts that get reported every cycle: open regulator inquiries, scheme attestation status, material litigation exposure, sanctions hit count and disposition, network rules tracker, merchant indemnity claim summary, change-of-control filings open, and licensing renewals due. Includes a worked board pack page that an AGC can put in front of a chair without rewriting.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

When a scheme operating regulation bulletin lands with a 90-day attestation deadline, work modules 1, 2, and 12.

When a CFPB, OCC, FCA, EBA, or RBI inquiry lands with a clock, work modules 1, 3, and 9.

When a merchant indemnity, chargeback, or BIN sponsorship dispute matures to litigation, work modules 4, 6, and 7.

When a sanctions hit escalates from operations and the BSA officer is asking for a sign-off position, work modules 5, 8, and 12.

What you get with this course

12 written modules in the Art of Service learning environment.
Downloadable templates for each module: attestation log, inquiry response shells, indemnity redline, escalation matrix, dispute tracker, BIN sponsorship redline, licensing register, data flow map, scheme litigation tracker, change-of-control checklist, board pack page.
Worked examples drawn from public regulator orders, scheme bulletins, and reported merchant litigation, mapped to the artefact each one informs.
A hand-built implementation playbook produced for the buyer's specific acquirer footprint, scheme set, and regulatory perimeter, delivered alongside course access.

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours of purchase: course access provisioned in the Art of Service learning environment.

Alongside course access: the hand-built implementation playbook tailored to the buyer's acquirer footprint, scheme set, and regulatory perimeter.

Recommended pacing: one module per working day across two and a half weeks, with the templates filled against the buyer's actual artefacts as each module closes.

Before and after

Before

Network rules, regulator inquiries, merchant disputes, and sanctions sign-off are run as four separate workstreams. The board sees four different reports. The schemes see four different signatories. The next attestation deadline lives in someone's inbox, not in a tracked log.

After

The four workstreams are run as one operating function with shared artefacts. The board reads one page. Each scheme attestation has a named signatory, a rule version, and a next review date. Regulator inquiries land into a templated response shell. Merchant indemnity disputes follow a clause-by-clause playbook. Sanctions escalation runs on a documented matrix that survives examination.

What happens if you do not address this

An acquirer AGC function run as four workstreams accumulates two predictable failures. The first is a missed scheme attestation deadline that surfaces as a fine and a rule-violation notice. The second is a regulator inquiry response that concedes more than necessary because the template was drafted under time pressure rather than off a worked shell. Neither failure is catastrophic on its own, and both compound into the GC's review and the board's risk appetite conversation.

Who it is for

Assistant General Counsel, Senior Counsel, or Deputy General Counsel inside a card acquirer, payment processor, payment facilitator, or BIN sponsor. Already qualified, already running a docket of network, regulatory, and commercial matters. Looking for the structured operating manual that turns a fragmented set of workstreams into one coherent function the GC, the board, and the schemes can all reference.

Who this is NOT for. This course is not for issuer-side counsel whose primary docket is consumer credit law and cardholder disputes. It is not for general commercial counsel without a payments docket. It is not for compliance officers without a legal seat. The artefacts assume the reader has signatory authority or direct access to a signatory at an acquiring entity.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Roughly 45 to 60 minutes of reading per module, plus 60 to 90 minutes of template work against the buyer's own artefacts. Approximately 18 to 24 hours total across the 12 modules, comfortably absorbed across two to three working weeks.

Why $199 is the right number

External payments counsel bills 850 to 1,400 USD per hour and produces work product on the matter in front of them, not the operating manual behind it. Industry conference sessions surface scheme bulletins and regulator priorities but stop short of the artefacts. Generalist GC training treats payments as one chapter in a broader curriculum. This course is the operating manual for the AGC seat at an acquirer or processor, written at the level of the artefacts, with templates that can be filled the same week.

FAQ

Does this assume a US acquirer or a global footprint?

The default treatment is global. The licensing, regulator inquiry, and privacy modules each name the US, UK, EU, India, Brazil, and Australia positions explicitly. The hand-built implementation playbook is tailored to the buyer's specific footprint.

Does this work for a payment facilitator or BIN sponsor rather than a direct acquirer?

Yes. Module 7 walks the legal architecture across acquirer, sponsor bank, payfac, and submerchant. The other modules are written so that the artefacts apply with the appropriate liability allocation regardless of which seat the buyer occupies.

Does this require sign-off authority to use?

The artefacts assume the reader has signatory authority or direct access to a signatory at an acquiring entity. Senior Counsel and Deputy GC roles also fit. Compliance officers without a legal seat will find the modules useful but the attestation and inquiry response artefacts require a legal signatory.

How current is the regulator and scheme content?

The course names the current rule families, examination priorities, and operating regulations as of the current cycle. The hand-built implementation playbook updates the references against the buyer's footprint at delivery.

Can the templates be used inside the buyer's organisation without further licensing?

Yes. The downloadable templates and worked examples are licensed for internal use by the buyer's organisation.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.