Interesting. Depending on who's POV. From a payment perspective, as the acquiring facility is with APT, then they are the merchant. The schemes ( ie, visa/mc) and the banks would view it like this. I have been advised by back merchant compliance that an ATO ruling last year stated settlement can not be in a different legal entity as the merchant facility. So I suppose they are the merchant in some respects and not in others. Will the regulator accept after pay trying to palm this title off to their clients? Maybe.. may be not
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