How the program reaches a merchant
BRAM operates on the acquirer, not the merchant. The network assesses the acquiring bank for merchants in its portfolio that breach standards, and the acquirer passes the consequence down. This is why processor behaviour in a category can change overnight with no warning to merchants: the acquirer’s own exposure changed first.
What the 2026 update changed
Research peptides and unapproved pharmaceuticals were named directly, which removed the ambiguity acquirers had been operating in. The practical result is that banks which were relaxed about the category two years ago are now either underwriting it strictly and knowingly, or exiting it.
The things that actually trigger it
- Miscoded merchant category codes
- Marketing copy making claims inconsistent with the stated product
- Transaction laundering, meaning volume from one merchant processed through another’s account
- Sustained excessive chargebacks