Background on AMEX Processing Limits and High-Risk Industries
In the merchant processing industry, most agents are aware of a key limitation: merchants are restricted to processing up to $1 million per year on American Express (AMEX) cards through third-party programs like OptBlue. Once this threshold is reached, AMEX requires the merchant to apply directly for an Establishment Service Agreement (ESA) number, effectively ending their ability to resell AMEX services through an agent or Independent Sales Organization (ISO).
High-Risk Industries Under OptBlue
The AMEX OptBlue Program identifies specific industry categories as high-risk. Agents and ISOs are permitted to sign merchants in these categories, but supporting documentation must be obtained before signing. Furthermore, agents must be able to provide this documentation within two business days upon request, though additional underwriting materials may also be required. Typical documentation includes:
- Merchant Processing Applications (MPA)
- Financial Statements
- Underwriting Support Documents
Prohibited Industries
AMEX also maintains a detailed list of industries that are prohibited from participating in the OptBlue program. Agents and ISOs are strictly prohibited from signing merchants operating in these industries. This list, outlined in the AMEX OptBlue Operating Rules, is updated semi-annually and was last revised in April 2023. Changes to the list are communicated through Compliance Bulletins in April and October of each year.
Why This Matters
Adhering to AMEX’s high-risk and prohibited industry guidelines is essential for compliance and maintaining your ability to resell AMEX services. Ensuring timely documentation and staying updated on changes to the operating rules will help agents and ISOs avoid potential penalties or account closures.
High-Risk Category
| Category | MCC | Supporting Documentation |
| Bail/Bail Bond (Fee Only) | 9223 | Ensure that the merchant only submits transactions for the bail bond fee. American Express reserves the right to exercise chargeback(s) for transactions submitted for actual bail or bail bond payments. |
| Charitable and Social Service Organizations | 8398 | Provide proof of tax-exempt status with a regulating tax authority or local council in accordance with applicable law. |
| Dating Services | 7273 | Provide proof that the Sponsored Merchant Prospect is a legitimate dating service and does not provide services such as: – Sexual-related services (e.g., escort or strippers) – Sexual services in return for payment (e.g., prostitution). |
| Digital File Hosting (Cyberlockers) | 4816 | Obtain proof of registration and licensure in compliance with applicable laws. Perform verification and monitoring to prevent illegal digital content (e.g., pornography, copyright infringement, or criminal acts). |
| Installment Payment Providers (Buy Now Pay Later – BNPL) | 5999 | Ensure the merchant meets eligibility requirements prior to accepting the card, in accordance with Section 8.3 of the April 2023 US Operating Regulations. |
| Online Pharmacy | 5912 | Provide attestation (format in Appendix C) and comply with licensing/inspection requirements of federal and state laws. Retain documents for seven years. |
| Online Tobacco (e-Cigarettes) | 5993 | Obtain notarized copies of documents as per Appendix C and retain for seven years. |
| Massage Parlors | 7297 | Verify legitimacy and licensure for therapeutic services. Ensure no sexual-related services are provided. |
| Political Organizations | 8651 | Verify registration as a political party or tax-exempt organization. |
| Securities Broker/Dealer | 6211 | Ensure transactions are only for broker fees. American Express may chargeback any transactions related to securities purchases. |
| Travel Agencies and Tour Operations | 4722 | Exempt from additional travel industry bonding documentation if not identified as a High CV Merchant. |
Prohibited Industries
| Category | MCC | Description |
| Airlines and Air Carriers (including Charter Airlines) | 3000–3302, 4511 | All airline and air carrier merchants, including charter airlines. |
| Bail/Bail Bond | 9223 | A sum of money paid by a criminal defendant for release from jail (does not include a bail bond fee). |
| Bankruptcy Services | – | Services related to bankruptcy or delinquent account recovery. |
| Bullion | – | Bulk metal in bars or ingots, including gold, silver, platinum, and palladium. |
| Car Rental Agencies | 3351–3441 | Branded car rental agencies such as Avis, Budget, Hertz, etc. |
| Check Cashing/Guarantee | – | Businesses offering check cashing services without a bank account. |
| Child Pornography | – | Illegal depiction of minors in sexually explicit content. |
| Collection Agencies | 7322 | Businesses recovering overdue funds, such as debt collection agencies and liquidators. |
| Commercial Leasing | 6513 | Leasing of land, real estate, equipment, or other property for periodic payment (excluding residential real estate agents and managers). |
| Credit Financing | 6010, 6011, 6012, 6051 | Includes financing services such as credit cards, personal loans, and mortgages. |
| Debt Repayment (past due or defaulted) | 7322 | Services involving payment collection for overdue debt. |
| Escort Services | – | Businesses or individuals offering companionship for a fee. |
| Foreign Exchange | 6051 | Currency exchange services by financial institutions. |
| Gambling | 7800, 7802, 7995 | Includes real-money betting, casinos, sports betting, lotteries, and games of chance. |
| Government-owned Postal Services | 9402 | Services provided by government-owned postal offices. |
| Marijuana-related Businesses | – | Includes manufacturing, distribution, and dispensing of marijuana products for recreational or medicinal purposes. |
| Multi-Level Marketing/Pyramid Selling | 5966, 5967 | Sales models involving recruiting participants for compensation, inventory loading, or restricted product returns. |
| Online Adult Entertainment | – | Businesses providing digital adult content. |
| Payday Lending | – | Lending money with high-interest rates for repayment with the borrower’s next paycheck. |
| Person-to-Person Payments | 6538 | Peer-to-peer payment platforms. |
| Prostitution | – | Businesses offering sexual services for payment. |
| Real Estate Down Payments | 6012, 6051 | Initial payments for real estate bought on credit. |
| Steamships and Cruise Lines | 4411 | Merchants operating steamship or cruise services. |
| Timeshares | 7012 | Selling partial property ownership for holiday home use. |
| Virtual Currency/Crypto | 6051 | Digital currencies not authorized by government entities. |
| Wire Transfers (In-person) | 4829 | Businesses specializing in money transfers. |
