Last updated: December 3, 2024
Stripe Payments Europe Limited, Stripe Technology Europe Limited and Stripe Payments UK Limited (collectively “Stripe”, “we”, “our” or “us”) take seriously our responsibility to protect the integrity of the financial system. We have our own legal obligations and policies designed to manage legal and financial risks.
In addition, Stripe has an obligation to protect consumers, Stripe Users, Financial Partners and third parties from an array of financial risks, including fraudulent activity and unauthorized cash flows. To achieve this goal, we have invested substantially in our advanced technology and tools to identify, prevent, and restrict activity that materially increases these risks. We use a combination of machine learning models, heuristics and human reviews to detect these behaviors and to help us determine whether an appropriate intervention should be applied. Stripe considers risks of this nature to be unacceptable in view of the responsibilities and obligations outlined.
As part of our efforts to mitigate unacceptable risks of this type, when identified and where necessary and appropriate, we will take certain actions on relevant User accounts. This Unacceptable Risk Policy describes the process that Stripe follows in these cases, including information about the appeals process open to Users in certain circumstances, and potential actions we may take on relevant accounts (including certain actions we make take under section 6.2 of the Stripe Services Agreement and sections 5.4 and 5.6 of the Stripe Payments Services Terms).
(Stripe retains discretion to reasonably determine any other risks that it considers to be unacceptable and treat under this policy.)
1. Who does this Unacceptable Risk Policy apply to?
This Policy currently applies to all Stripe Users that have a Stripe account in the EEA, UK or Switzerland.
2. When might this Policy apply to a User’s account?
When activity on a User’s account is deemed to have become an unacceptable risk to Stripe, Stripe may determine that it can no longer continue providing its services to the User (e.g., Stripe cannot continue processing transactions on the User’s account).
3. What actions might Stripe take on the relevant account?
Actions that Stripe may take on a User’s account include, but are not limited to:
- Restricting or pausing charges so the User will not be able to accept new payments.
- Restricting or pausing payouts so the User will not be able to transfer funds to their bank account.
- Reversing payments to the originator of a transaction.
- Commencing the process of closing the User’s Stripe account.
4. How will a User know that Stripe has taken action on their account?
Stripe will notify the User by email that their account is being actioned, and may include the following information:
- Category of reason for the account being actioned.
- Specific actions being applied to the account.
- Relevant deadlines for when these actions may cease (where applicable).
- Information on how to appeal Stripe’s decision in relation to their account.
5. If available, how can a User appeal the action applied to their account?
When a decision is made under this Unacceptable Risk Policy, in certain circumstances a User will have the option to appeal Stripe’s determination. The primary purpose of an appeal in these cases is to give the User the opportunity to provide additional information to Stripe to be taken into consideration to inform a decision as to whether all or some of the relevant actions Stripe has taken in relation to the account should be disapplied. In a typical appeals process:
- Stripe will notify the User of the actions taken on the account and provide information on how and when to submit an appeal (which can typically be done through the Stripe Dashboard).
- The User will be requested to provide additional information, and a manual review will be carried out by Stripe where this additional information will be considered together with the all other information held in order to inform a decision as to whether all or some of the relevant actions Stripe has taken in relation to the account should be disapplied (e.g., reverse the decision to close the user’s Stripe account).
- The User will be notified by email as to whether their appeal has been successful or unsuccessful.
- A User whose initial appeal is unsuccessful may have the opportunity to make another appeal through the Dashboard.
- Where a User is unsuccessful in subsequent appeals, they will be notified by email of the outcome of the appeal.
6. When can a User payout the remaining balance from their Stripe account to their bank account?
Where a User’s Stripe account is being handled under this Unacceptable Risk Policy, in line with industry practice, Stripe will typically restrict or pause payouts to the User’s bank account for up to 120 days from the date the User receives the initial email notifying them of the actions applied to their account. The primary purpose for pausing payouts is to cover potential refunds, disputes or chargebacks on the account. (For this reason, it is possible that a User’s account balance reaches zero with no additional funds to payout to a User’s bank account after 120 days.) In addition, within these 120 days, Stripe will continue to carry out its internal review of the User's account and, where applicable, review appeals submitted by the User. After 120 days, Stripe will typically pay the remaining balance on the User’s account out to the relevant bank account (subject to Stripe continuing to hold an appropriate proportion of the balance to cover future risk of refunds, disputes or chargebacks).
7. When will Stripe enforce its contractual right to cancel payouts of the remaining balance in a User’s Stripe account to their bank account?
In certain cases handled under this Policy, at 120 days, Stripe may enforce its contractual right (under section 5.6 of your Stripe Payments Services Terms) to cancel the payout of the remaining balance in a User’s Stripe account to their bank account. This outcome may be applied in cases where Stripe’s review has determined that the unacceptable risk posed by the User’s account to Stripe will continue beyond 120 days, or for other reasons (e.g., where Stripe is obliged to do so under law). Stripe’s determination in these cases may be based on confidential criteria that are necessary for proper risk management and to achieve Stripe’s goal of protecting Users, consumers, Financial Partners, third parties and Stripe itself from undue financial harm and loss. In addition, Stripe may be restricted by law, regulation or Governmental Authority, in some situations, from disclosing certain information to Users about this determination. In the rare event a User has payouts to their bank account canceled under this Policy, they will be notified by email of this treatment following 120 days after receipt of the initial email that notified them of the actions taken on their account under this Policy.
Note
This Policy is designed to supplement any agreements that a User already has in place with Stripe (the “Stripe Agreements”). If there is any conflict between this Policy and the Stripe Agreements, the Stripe Agreements will prevail.
As a general reminder, if you are dissatisfied with Stripe’s services for any reason you can submit a complaint to Stripe online.