> ## Documentation Index
> Fetch the complete documentation index at: https://www.bitnob.dev/llms.txt
> Use this file to discover all available pages before exploring further.

> ## Agent Instructions
> Bitnob API requests authenticate with an `X-Auth-Client` API key header against https://api.bitnob.com.
> Always use the sandbox environment for testing. Never put live API keys in sample code.
> Money amounts are integers in the smallest unit of the currency (satoshis for BTC, cents for fiat). Never use floats.
> Every state-changing request takes a client-supplied `reference` and must be treated as idempotent on retry.
> Quotes expire. Re-quote rather than reusing a stale quote id.

# Module 9: Compliance, PCI-DSS, and scheme requirements

> PCI-DSS and scheme requirements for virtual card programmes, and the controls auditors expect.

## Objective

This module equips engineering, compliance, product, and executive teams with a clear understanding of:

* What compliance frameworks (like PCI-DSS) apply to virtual card systems
* How Visa, Mastercard, and other scheme rules affect what you build
* How to stay ahead of audits, regulator queries, and partner evaluations
* What technical and process controls must be in place to be compliant and audit-ready

## Understanding PCI-DSS for virtual cards

PCI-DSS (Payment Card Industry Data Security Standard) is the global benchmark for how cardholder data is stored, processed, and transmitted.

While your system may not be storing full PAN/CVV (as cards are issued via a licensed third party), you may still:

* Display partial card data
* Transmit data during card creation, top-up, or spend
* Log metadata (e.g. last 4 digits, BIN, MCC)
* Proxy card information through your frontend or backend

**Your PCI responsibilities (as a card distributor or integrator):**

| Area | Minimum Required |
| - | - |
| PAN handling | Never store or transmit full PAN/CVV unencrypted |
| Logging | No PAN/CVV in logs or plaintext |
| Transport | Enforce HTTPS with TLS 1.2+ |
| Access Control | Role-based controls and encryption at rest |
| Key Management | Rotate secrets and API keys frequently |
| System Monitoring | Audit access to card-related APIs and UIs |
| Staff Training | Annual PCI awareness training for devs and support |

## Card scheme rules (Visa, Mastercard, etc.)

Your issuing partner is bound by Visa and Mastercard scheme rules, and so are you indirectly.

**Key expectations:**

| Area | Rule |
| - | - |
| BIN Usage | BIN must align with use case: prepaid, debit, consumer/corporate |
| MCC Blocking | Certain MCCs (6051, 7995, 4829) require explicit control |
| Refund Handling | Refunds must not be routed in a way that creates AML risk |
| Chargeback Handling | Must respond to disputes within scheme SLA (typically 30 days) |
| Cross-Border Transactions | Must inform users of FX and apply correct markup |
| Sanctions & Jurisdiction | Cannot issue to or support users from embargoed countries |
| Scheme Reporting | Volume, dispute rate, chargeback ratios must be monitored and reported |

If your platform enables top-up → spend → withdraw, it may fall under stored value or e-money compliance zones, which triggers additional local obligations (e.g., in the EU, UK, or Nigeria).

## Examples of compliance failures

| Case | What Happened | Consequence |
| - | - | - |
| Stored PAN in logs | Dev environment captured PAN in console output | PCI breach, potential fine |
| Unauthorized MCC use | Enabled card for MCC 6051 | Scheme compliance violation |
| Delayed chargeback response | Failed to respond in 30-day SLA | Merchant debited, issuer penalized |
| Refund to terminated card | Issued refund to float, no audit trail | Treasury exposure, audit gap |

## Regulatory zones that may apply

Even if you're not directly licensed, your platform must design for:

| Jurisdiction | Risk |
| - | - |
| US | Stored value, prepaid compliance (FinCEN) |
| EU | PSD2 and e-money directive (for float handling) |
| Nigeria | CBN e-wallet and card issuance circulars |
| UK | FCA oversight for distribution models |
| India | RBI rules for prepaid instruments |

You are a regulated surface, even if not a licensed entity. Design like you're regulated.

## Partner due diligence readiness

Issuers, banks, and card processors may request due diligence and audit responses. You must be able to demonstrate:

* Secure card issuance processes
* KYC enforcement prior to high-risk MCCs
* Card freeze/terminate workflows
* Refund reconciliation across wallet/float/card
* Transparent ledger tracking and transaction matching
* Chargeback handling playbooks

## Developer & product responsibilities

| Role | Responsibilities |
| - | - |
| Engineers | Never log or store PAN/CVV; verify TLS; sign webhooks; monitor access logs |
| Product Managers | Verify MCC restrictions, spend limits, refund policies, user flow limits |
| Compliance Officers | Maintain risk registry; monitor chargeback and refund logs |
| Treasury | Ensure float reconciliation and partner compliance with FX/cross-border rules |
| Support | Know SLAs for refunds, chargebacks, and reversals |

## Audit checklist (internal readiness)

* TLS 1.2+ enforced on all endpoints
* No PAN/CVV in logs or response bodies
* 2FA enabled for all admin/card dashboard access
* Internal card operations are audit-logged
* Webhooks signed and verified
* Refund/chargeback SLAs met 99% of the time
* KYC enforced before spending on MCC 6051, 7995, 4829
* Partner card scheme documentation accessible
* Float exposure reviewed weekly
* Compliance reviews logged quarterly

## Module 9 knowledge check

### 1. What does PCI-DSS primarily govern?

A. Merchant payouts

B. Card issuance business models

C. Storage and transmission of cardholder data

D. Revenue reporting

**Answer:** C

### 2. What must you never store or log?

A. Merchant name

B. PAN/CVV in plaintext

C. MCC codes

D. BIN metadata

**Answer:** B

### 3. Which MCCs are considered high-risk and require compliance safeguards?

A. 5732 and 5812

B. 7995, 6051, 4829

C. 4411 and 4511

D. 5045, 5065

**Answer:** B


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