Navigating Visa VIRP Compliance for a Crypto On-Ramp Provider

The Situation

Our client operated a fiat-to-crypto on-ramp serving retail users across multiple geographies. They'd grown quickly — processing mid-eight figures monthly — when their acquiring bank received a VIRP inquiry from Visa.

The inquiry flagged elevated chargeback rates and concerns about transaction laundering risk. The client had 30 days to respond with a remediation plan or face termination.

What We Did

1. Rapid Risk Assessment (Days 1-3)

We embedded with the client's ops team and conducted a full transaction-level review. We identified the actual drivers of chargebacks: a mix of friendly fraud (users disputing after receiving crypto), confusing descriptor names, and some genuine first-party fraud.

2. Chargeback Mitigation Framework (Days 4-10)

We implemented a multi-layered approach:

• Pre-authorization velocity checks — Flagging rapid repeat purchases from same card/device
• Enhanced identity verification — Adding liveness checks for transactions over threshold
• Improved descriptors — Clear merchant names that users would recognize on statements
• Cooling-off period — Delayed crypto delivery for first-time users, reducing friendly fraud window

3. Transaction Laundering Controls (Days 5-15)

The VIRP inquiry specifically mentioned transaction laundering risk. We built a monitoring framework that:

• Tracked destination wallet clustering
• Flagged unusual patterns (same wallet receiving from multiple unrelated users)
• Implemented automated holds for high-risk patterns pending manual review
• Created audit trails that demonstrated active monitoring

4. Response Package (Days 15-25)

We prepared a comprehensive response package for Visa that included:

• Root cause analysis with supporting data
• Detailed remediation plan with implementation timeline
• Evidence of controls already implemented
• Projected chargeback trajectory with interim milestones
• Ongoing monitoring and reporting commitments

The Outcome

Why It Worked

The key wasn't just checking boxes — it was demonstrating to Visa (through the acquirer) that the client understood the risks, had implemented meaningful controls, and was committed to ongoing monitoring. Networks don't want to terminate merchants; they want to see that risks are managed.

We also helped the client reframe internally: the VIRP inquiry wasn't a crisis to survive — it was an opportunity to build controls that would be required anyway as they scaled. The framework we built became a competitive advantage when pursuing additional acquiring relationships.