If you're running a sweep-style product in the US and still on the fence about…
So I almost got hosed by this Paysera mess last quarter—rolled up in some audit and suddenly our PSP starts screaming about "supply-chain liability." Go easy on me, but I thought "oh great, now we've got to rework the whole damn MID chain." Has anyone else seen their processor start red-flagging stuff like rolling reserves or FTD spikes out of nowhere after AB831?
New to this, soaking it up.
I woke up this morning to an email titled *Re: Immediate Compliance Deadline – Rolling Reserve Adjustment* and stared at my screen for thirty seconds wondering if I’d misread the date on AB831 again. Paysera wasn’t screaming—they were quietly rewriting the MID chain in a way that’s bleeding straight into our GGR, not the other end of the funnel like everyone assumed. The Stake.us amended complaint did more than name the processor; it named the *pass-throughs*. That means the DOJ is tracing the cash until it hits the affiliate where they actually can attach liability—KYC gaps, chargeback patterns, even affiliate payout waterfalls. If your rev-share contract still has a clause that says “PSP bears all risk” dated after May 2023, you’re already underwater because the courts are reading *successor liability* into the supply chain. I could be wrong, but Paysera’s reserve hike wasn’t about their own risk appetite; it was a forward price on an impending claw-back they priced into the MID terms three weeks before the amended complaint dropped.
Do the math before you sign.
What do they mean by "successor liability" in this context? I’ve heard the term before but never really tied it to something as scary as my whole MID chain suddenly rewriting itself. Does it mean if the processor gets hit, the debt crawls back up to me somehow?
Asking daft launch questions — that's the job.
@PayAndPlayOffshore
That’s the scary bit, yeah. The debt doesn’t crawl—it skips. One day your PSP is just tightening the screws on your rolling reserve, the next the DOJ’s civil division has already filed to attach the MID that’s holding your affiliate payouts. Paysera themselves priced that into your new MID terms before the amended Stake.us complaint even hit PACER. You’ve got an affiliate rev-share sitting in a wallet that’s now part of a shell structure Paysera used to shield an old exposure—successor liability means the receiver can claw that back and reassign it to any entity that ever touched the chain, including the last link before the cash hits the affiliate. Check your contract: if it says “PSP bears all risk” after May 2023, good luck enforcing it. Courts are reading successor liability straight through the supply chain now, not just at the processor level. Read the MIDs, not the marketing emails.
The contract tells you more than the pitch.
Back in aught-seven when we launched that Antigua licence for a soft-credit B2C site, we got caught by an old unpaid debt the processor had shelved in the Mid-Co account. One morning our rolling reserve jumped from 10 % to 35 %, with no warning and no new chargeback surge. Paysera weren’t screaming—they’d already told their own bank the exposure was “re-payable by the merchant family.” Turns out the original processor’s failure hit the chain because the acquiring MID was still booked under the same corporate shell we had used for the rev-share agreement. When the receiver clawed back every dollar in that MID they didn’t just take the shell—they rolled the liability up to anyone who had ever touched the wallet. The judge called it successor liability: the debt walks back along the supply chain until it lands on whoever holds the last warm hand.
Wait, so the Stake.us thing isn't just about the operator getting nailed—it's about Paysera and then the *affiliate* balance being next on the chopping block if the KYC chain has holes? So if my rev-share payouts to an affiliate are still sitting in the same MID that Paysera started red-flagging, that claw-back could literally walk back up and hit my GGR because the "successor liability" now means the processor's debt becomes my debt?
Learning from the operators who did it, go easy 🙏