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Visa 10.5 - Visa Fraud Monitoring Program (VFMP)

TL;DR
  • VFMP was retired on 31 March 2025 and folded into VAMP on 1 April 2025. Nobody is enrolled in it today
  • The dispute condition still exists and is still numbered 10.5. Visa retired the program behind it
  • If your acquirer says you're in a fraud monitoring program, it's VAMP, and the numbers are different
  • Everything below the overview describes the retired program. It's kept for anyone reading an old notice or an old runbook
VFMP was retired on 31 March 2025

Visa retired the Fraud Monitoring Program as a program and folded it into VAMP (Visa Acquirer Monitoring Program) on 1 April 2025. Nobody is enrolled in VFMP today, and no VFMP fine has been assessed since then. The name survives only on this dispute condition, which is still numbered 10.5.

If your acquirer has told you that you're in a fraud monitoring program, it's VAMP, and the numbers are different. See Network Programs Reference for what's live: 1.5% merchant excessive, a 1,500 combined fraud-and-dispute floor, and per-dispute fees rather than the monthly assessments below.

Everything on this page below the overview describes the retired program. It's kept for anyone reading an old notice or an old runbook.

Disputes arising from VFMP compliance violations. Issuers could file under this code while the program ran.

Overview​

Issuers filed this code against merchants sitting in Visa's Fraud Monitoring Program. The trigger was either a missed program requirement or a fraud transaction out of an enrolled account.

When This Code Applies​

  • The merchant was enrolled in VFMP
  • The transaction was fraudulent and came from that merchant
  • The merchant missed a VFMP compliance requirement
  • The fraud rate blew past the program thresholds

VFMP Thresholds​

Historical. These applied until 31 March 2025 and apply to nobody now. VAMP replaced them with a single combined fraud-and-dispute ratio.

Standard VFMP Thresholds​

TierFraud Basis PointsFraud Transactions
Early Warning65 bps AND75 transactions
Standard90 bps AND100 transactions
Excessive180 bps AND1,000 transactions

VFMP Timeline​

Also historical. VAMP charges per dispute instead: US$8 per CNP dispute at merchant excessive, not a flat monthly assessment.

StageConsequence
Month 1-4Identification, remediation required
Month 5-8$25,000/month fines
Month 9+$75,000/month fines
Month 12Card acceptance termination possible

Conditions for Valid Dispute​

Issuer Must Verify​

  1. The merchant was enrolled in VFMP at the time
  2. The transaction itself was fraudulent
  3. The filing landed inside the program timeframes

Merchant Situation​

  • You were already under enhanced monitoring
  • Your representment options were thin
  • Every dispute you filed drew extra scrutiny

Representment Options​

Once you were in the program, you didn't have many moves.

1. Transaction Was Authorized​

Evidence required:

  • Strong authentication proof (3DS with ECI 05)
  • Cardholder correspondence
  • Device/IP matching prior purchases

2. Fraud Prevention Was Applied​

Evidence required:

  • Fraud screening records
  • 3DS attempt logs
  • Declined transaction history showing controls

3. Exit VFMP Status​

Getting the fraud rate under the thresholds beat winning cases. Prevention mattered more than representment.

Prevention Strategies (VFMP Exit Focus)​

Immediate Actions​

  1. Enable 3DS 2.0 - Get liability shift on all transactions
  2. Tighten fraud scoring - decline more of the borderline orders
  3. Review product/pricing - some products attract fraud and have to go
  4. Velocity limits - cap orders per customer, per card and per IP

Monitoring​

  1. Daily fraud review - Don't wait for monthly reports
  2. Track basis points - Know your real-time fraud rate
  3. Dispute categorization - know where your fraud is coming from

Customer Verification​

  1. Enhanced verification - confirm the order by phone or email
  2. Delivery confirmation - require a signature on every delivery
  3. New customer friction - make first-time buyers clear a higher bar

Win Rate Expectations​

Representment during VFMP was an uphill fight:

Defense TypeExpected Win Rate
3DS fully authenticated70-85%
Strong prior relationship40-60%
Standard evidence15-30%

Reality: spend the effort on prevention, not on representment.

Exiting VFMP​

Exit Requirements​

  • Fraud rate below thresholds for 3 consecutive months
  • Evidence that you'd closed the compliance gaps
  • Your acquirer confirming you're out

Exit Strategy​

  1. Aggressive fraud blocking - accept fewer of the risky orders
  2. 3DS on everything - push the liability shift as far as it goes
  3. Product review - pull the items that keep attracting fraud
  4. Customer segmentation - whitelist the customers you already trust

Common Mistakes​

  1. Ignoring VFMP enrollment - hope isn't a strategy
  2. Continuing normal operations - if nothing changes, the fraud rate doesn't either
  3. Fighting all disputes - Waste of resources during VFMP
  4. No root cause analysis - you'll be back in the program
  • 10.1 - EMV Counterfeit
  • 10.2 - EMV Non-Counterfeit
  • 10.3 - Other Fraud Card Present
  • 10.4 - Card Not Present Fraud

Next Steps​

In VFMP program?

  1. Immediately implement 3D Secure
  2. Set up dispute alerts to reduce dispute count
  3. Review fraud rules → Tighten velocity checks
  4. Follow the Reduce Chargebacks Fast playbook

Get out of VFMP:

  1. Reduce fraud ratio below thresholds for 3 consecutive months
  2. Work with processor on remediation plan
  3. Consider temporarily blocking high-risk transactions

See Also​

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