Two layers, one card: where Swype's compliance ends and yours begins

swype

COMPLIANCE • PARTNERS & MERCHANTS

Who owns compliance: Swype or your platform?

Compliance on Swype-issued cards is a shared responsibility. This article draws the line between what Swype handles and what stays with you as the B2B client.

AUDIENCE

B2B Clients

SCOPE

Responsibility split

LAST REVIEWED

June 2026

Summary: Swype manages issuer, scheme, and card-level compliance. You remain responsible for ensuring your own end-user flows, marketing, and use cases comply with applicable laws and card network rules.

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The short version

Think of it as two separate layers. Swype is responsible for everything happening below the card — the issuer relationship, the card network rules, and how the program itself is structured. You're responsible for everything happening above the card — how your end users interact with your product, what you tell them, and how you use the card to deliver your own use case. Neither layer covers the other.

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What Swype is responsible for

Swype owns compliance at the issuer, card scheme, and program level:

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Maintaining the issuing bank relationship and program-level licensing

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Meeting Visa/Mastercard scheme rules at the card program level

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Defining and enforcing the KYC framework applied at sign-up

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Maintaining and enforcing the restricted & sanctioned countries list

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Card-level transaction monitoring required by the issuer and schemes

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What stays with you as the B2B client

Swype doesn't see, control, or take responsibility for how you build on top of the card program. That includes:

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Your own end-user onboarding flow, terms, and disclosures

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Marketing claims made to your end users about the card or program

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Ensuring your specific use case is lawful in the markets you operate in

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Compliance with card network rules that apply specifically to your business model or industry

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Any local licensing your own business needs independent of the card program

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A practical example

Swype's side: the card itself is correctly issued, the cardholder passed the standard KYC flow, the card isn't tied to a restricted jurisdiction, and the transaction clears the network correctly.

Your side: whether your marketing accurately described what the card does, whether your terms disclosed fees correctly, and whether your specific industry vertical is permitted to use prepaid cards the way you're using them in each market you serve.

Important

This split doesn't change based on contract language or assumptions made during sales conversations. If you're unsure which side of this line a specific obligation falls on, ask before launching — not after a regulator or card scheme asks first.

Not sure where a specific obligation sits?

Our compliance team can review your specific use case against this split before you launch.

Contact Compliance →