The proposed FTC order in the Nuvei case does not make one chargeback an automatic reason to terminate a merchant. It creates a layered control system: two merchant groups are banned outright; defined Covered Clients receive enhanced screening and recurring review; every client gets monthly chargeback calculations; and an investigation begins only after both a rate and a count threshold are exceeded in two of the previous six months. Once that investigation starts, Nuvei would have 60 days to close every processing account or produce a written report establishing, by clear and convincing evidence, that the relevant practices are not unfair or deceptive.
Those obligations are not yet a final judicial finding. The complaint was filed September 3, 2026 and the stipulated order September 4. The FTC case page still listed the case as pending at 4:16 AM Pacific Time on September 6. Nuvei neither admits nor denies the allegations except for jurisdiction, and deadlines run from court entry.
The question this map answers
Which merchants would the proposed order ban, which clients enter the enhanced-control lane, how do the recurring numerical triggers work, and what evidence is required before processing may continue after an investigation?
MyMap reviewed the complaint, stipulated order, FTC release, commissioners' statement, and case page. A Client obtains payment processing from a Nuvei defendant. A Covered Client is a narrower class defined by sales channel, product, or recent enforcement history. A Chargeback Rate is the month's chargebacks divided by card transactions. A trigger starts an investigation; it is not a fraud finding. A hard ban bypasses screening because processing would be prohibited altogether.
The complaint describes allegations, not adjudicated facts
The FTC alleges that Nuvei entities enabled Reimage and other merchants to reach cardholders through acquiring, payment-facilitator, merchant-of-record, and other processing relationships. The complaint says Nuvei processed more than $30 million for Reimage from 2017 through 2023 and alleges that merchant applications, account structures, category codes, and transaction routing concealed the operation's location, telemarketing activity, or chargeback profile.
The alleged evidence sequence matters more than any single alert. According to the complaint, consumer complaints reached a Nuvei entity as early as 2015; Mastercard flagged Reimage in a 2019 audit; Microsoft test-shopped the sales path in early 2020; and Visa rejected Reimage's response and imposed a €25,000 fine in May 2020. The FTC alleges processing continued and that transactions were distributed among accounts and processors, reducing the chance that one account crossed a network threshold.
Those are the FTC's claims about past conduct. The stipulated order says the defendants do not admit or deny them. MyMap therefore draws the complaint evidence in a separate dashed lane and does not reuse it as proof that any current Nuvei client is deceptive.
Two categories would be banned without a threshold test
The first order lane is categorical. Nuvei would be permanently prohibited from payment processing for a person selling technical-support products or services through telemarketing or through pop-up messages about a device's security or performance. The order's technical-support definition excludes ordinary software customer support unless the software purports to repair, maintain, or improve a device's performance or security.
The second ban covers a person Nuvei knows or has reason to know is on Mastercard's MATCH list for seven specified reasons, including excessive chargebacks, fraud, laundering, merchant collusion, or illegal transactions. The map keeps that list-specific ban distinct from general chargeback monitoring: one dispute does not put a merchant in the ban.
The order would separately prohibit false statements in merchant-account applications and tactics that evade bank or card-network risk programs. Examples include distributing transaction volume across accounts or billing descriptors, using shell companies to seek more accounts, splitting one transaction into smaller transactions, and using prevented-chargeback services without examining why the rate is excessive.
Covered Client is a defined risk class, not a synonym for every merchant
A Client becomes a Covered Client through any of three gates. The first is selling consumer goods or services through outbound telemarketing. The second is selling a technical-support product, consumer computer software, a business opportunity, business coaching, a negative-option product, a healthcare-related product, or debt relief. The third is having been named during the preceding ten years in a public complaint, settlement, or assurance involving fraud or unfair, deceptive, or abusive practices by the FTC, another federal enforcement agency, or a state attorney general.
Before onboarding a prospective Covered Client, Nuvei must collect and test an evidence bundle: business model and sales methods; two years of marketing; principals, controlling people, majority owners, names and aliases; operating addresses; two years of processor and bank relationships; five months of chargeback and ACH return rates; six months of statements when available; and recent monitoring, termination, and public-enforcement history.
Nuvei must assess accuracy by reviewing complete websites, statements, current marketing, scripts, and search results. If that work shows specified deception, missing disclosures, unauthorized billing, or an FTC Act or Telemarketing Sales Rule violation, it must not provide processing, ACH, ISO, or sales-agent services.
Recurring monitoring splits into an enhanced lane and an all-client lane
For Covered Clients, monthly monitoring would examine websites from an IP address not associated with Nuvei, complaints, chargeback and ACH return rates, unusual transaction patterns, search results, and marketing. Test calls would occur at least quarterly. Rates must be calculated per account and across all accounts, closing the blind spot created by divided activity.
Every Client—not only a Covered Client—would enter a baseline chargeback lane. Nuvei must calculate rates monthly, per account and in aggregate. A qualifying month requires a rate above 1.0% and more than 75 chargebacks, and both must occur in any two of the previous six months. One high-rate month, 76 disputes below 1.0%, or a rate above 1.0% with 75 or fewer disputes does not trigger investigation.
Covered Clients using ACH have an additional trigger: in any two of six months, the Total Return Rate must exceed 2.5% and the client must have more than 40 returned ACH debit transactions in a month. The order again requires account-level and client-level aggregation.
Investigation leads to a timed close-or-document decision
After a trigger, the proposed order requires a prompt reasonable investigation. The listed steps include refreshing the onboarding evidence; checking transaction authorizations; contacting financial institutions and Better Business Bureaus; reviewing websites from an independent IP address; searching for government enforcement; test shopping and calling; and identifying every processing account the client has with Nuvei.
Within 60 days after that investigation begins, Nuvei must stop processing and close all of the client's processing accounts unless it drafts a written report establishing facts, by clear and convincing evidence, that the relevant business practices are not deceptive or unfair under Section 5 of the FTC Act or the Telemarketing Sales Rule. For a Covered Client, an identified tactic to avoid fraud monitoring produces a separate prompt-closure rule rather than the 60-day exception path.
The report is a decision record, not a waiver. The order also requires annual compliance reporting, acknowledgment by relevant personnel, and specified records created for ten years and retained for five.
Court entry controls every deadline
The stipulated paper states that judgment of $4.85 million would be entered and payment would be due within seven days of entry. The 60-day review of existing clients, annual report, personnel acknowledgment, and other clocks also depend on entry. On September 6, the FTC case page still said Pending, and the posted order did not establish a separate observed entry date.
“The parties stipulated” does not prove the court entered every term, and “the order requires” does not mean the complaint allegations were adjudicated. A live tracker should separate filing, entry, payment, initial review, and later compliance reports.
Confirmed, derived, and still unknown
The controlling sources confirm the complaint and order filing dates; the pending case-page status at observation; the no-admission clause; the proposed categorical bans; Covered Client definition; onboarding and monitoring fields; monthly and quarterly cadences; dual-threshold tests; investigation steps; 60-day decision rule; $4.85 million judgment; and entry-dependent deadlines.
MyMap derives the two-track architecture, the evidence-bundle checklist, and the state sequence from trigger to investigation to close-or-document. These structures reproduce the order's conditions; they do not label a merchant risky, prove the complaint, or predict how Nuvei will implement the controls.
The sources leave unknown when the court will enter the stipulated order; whether the posted text will change; when payment or the first compliance deadlines will occur; which current clients meet the Covered Client definition; which clients cross a trigger; how Nuvei will document its investigations; whether the FTC will dispute a report; and how much redress any individual consumer will receive.
The practical next step is one client-level record that cannot be fragmented by account: owners and aliases, products and channels, every account, monthly transaction and dispute counts, aggregate rates, complaints, marketing snapshots, test-call results, trigger dates, investigation start, and the signed close-or-document decision. Keep allegations, signals, triggers, and findings separate.