Account Suspension & Blocking Rules

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These rules describe the conditions under which PT UNIT GLOBAL SYSTEM may suspend or close a merchant account, the notice that we provide, how funds are handled during suspension, the investigation timeline, and the appeal process available to affected merchants.

1. Triggers for suspension

UnitPay may suspend a merchant account, in whole or in part, where we determine on reasonable grounds that one or more of the following conditions exist. Suspension may be applied to specific functions (settlement, withdrawals, new transactions) or to the account as a whole, proportionate to the underlying trigger:

  • Material violation of the Acceptable Use Policy, including processing in a prohibited category.
  • An AML or CFT alert that the AML Compliance Officer adjudicates as warranting protective action.
  • Sustained chargeback ratio above 1.0% in any single calendar month, or above 0.65% for three consecutive months.
  • Court order, regulator instruction (Bank Indonesia, OJK, PPATK, BSSN), or valid legal process requiring suspension or freeze.
  • Failure to refresh KYC or KYB documents within 30 days of a triggered refresh request.
  • Material adverse change in the merchant's regulatory status (licence revocation, sanctions designation).
  • Suspected account takeover or compromise of merchant credentials.
  • Failure to settle outstanding amounts owed to UnitPay (chargeback liability, fee balance, refund recovery).
  • Material misstatement at onboarding, including undisclosed beneficial ownership or business model.
  • Pattern of customer complaints sustained at a level inconsistent with normal commercial operation.

Where multiple triggers apply, the most severe drives the response. Where a graduated response is appropriate (warning, restriction, suspension, closure), UnitPay applies the steps in order unless the seriousness of the trigger justifies skipping ahead.

Triggers are intended as a non-exhaustive guide rather than an exhaustive list. Other circumstances that, in UnitPay's reasonable judgement, present material risk to the integrity of the payment system, to other merchants, or to customers may also justify protective action.

2. Notification

Except where prior notice is prohibited by law, regulator instruction, or anti-tipping-off provisions, the merchant receives notification of suspension by email to the address on file at legal@unitpay.net and through an in-cabinet notice within 24 hours of action.

The notification states the reason for suspension at the level of detail consistent with our legal obligations, the scope of the action (full account, specific payment methods, specific functions), and the next steps required of the merchant. Where the suspension is intended as a graduated step rather than a terminal action (for example, a 14-day pause to allow remediation), the notification sets out the remediation criteria and the timeline.

Emergency suspensions taken on regulator request, on AML grounds, or to prevent ongoing harm may be applied without prior notice. In those cases, post-action notification follows as soon as it is lawfully permissible.

Notifications to merchants are written in plain language to the extent the underlying legal posture permits. Where regulatory or contractual reasons require formal language, the notification is accompanied by a plain-language summary so that the merchant understands what has changed and what is required next.

3. Fund holding during suspension

When an account is suspended:

  • The merchant balance is frozen; no new withdrawals are processed pending review.
  • Settled-but-unwithdrawn funds remain in our trust arrangement maintained for that purpose, in line with Bank Indonesia segregation requirements applicable to payment service providers.
  • Pending transactions may be reversed or held pending review; refunded transactions are processed in line with the Refund and Chargeback Policy.
  • A reserve sufficient to cover anticipated chargebacks, refunds, and regulator holds is set aside for at least 180 days (longer where the chargeback profile or legal-process requirement justifies).
  • Settlement of new transactions is paused but customer-side payments may continue to be accepted where the suspension scope is partial; affected merchants receive a clear instruction at notification time.
  • Where regulator instruction or court order specifies a freeze, no funds move out of the segregated balance until the order is lifted or modified, regardless of merchant request.

Funds are not used by UnitPay for any purpose other than settling the merchant's obligations and complying with regulator and legal requirements.

The 180-day reserve window reflects standard card-network chargeback liability tail; longer holds apply only where specific legal-process requirements (court order, regulator instruction, ongoing investigation) extend the period.

The reasoning for any extended hold is documented in the case record and shared with the merchant to the extent that disclosure is lawful. Where part of the held balance becomes free of contingent liability before the full window expires, partial release is processed without waiting for the full period to elapse.

4. Investigation period

Standard investigation completes within 30 to 60 working days from suspension. Complex cases (multi-jurisdictional, requiring regulator coordination, or involving extensive evidence review) may extend longer; we communicate progress at least every 30 days while investigation is open.

Investigations are conducted by compliance staff with no direct commercial relationship to the merchant under review. Where the case touches matters that the AML Compliance Officer is conflicted on, the investigation is escalated to a substitute reviewer with the same authority.

Merchants are invited to submit evidence relevant to the investigation by writing to compliance@unitpay.net. Evidence must be specific to the trigger; the AML Compliance Officer reviews submissions and may follow up with targeted questions.

Investigation outcomes fall into four categories: full reinstatement, conditional reinstatement subject to defined remediation steps, account closure, and reinstatement with elevated risk-tier and monitoring posture. The decision is documented in writing with the supporting rationale.

Investigations that touch on AML or sanctions matters are conducted in line with the anti-tipping-off framework: certain investigative steps and findings cannot be shared with the merchant, and the merchant should not interpret information silence as inactivity.

5. Appeal process

A merchant may appeal a suspension decision in writing to the AML Compliance Officer within 30 days of the original decision, addressed to compliance@unitpay.net. Appeals must state the basis for appeal and include any new evidence relevant to the underlying trigger.

The AMLCO reviews the appeal within 14 working days and issues a written final decision. The reviewer is independent of the original decision-maker so that the appeal receives a fresh assessment rather than a confirmation pass.

If the merchant remains dissatisfied with the outcome, the merchant may escalate to LAPS SJK at https://lapssjk.id, the OJK-recognised alternative dispute resolution body for the financial services sector, or contact OJK directly through the consumer hotline 157, in line with our Dispute Resolution and Complaint Handling framework.

UnitPay does not retaliate against merchants for raising appeals or external escalations. Penalising a merchant for using these channels would itself be a separately reportable breach of POJK 18/2018.

Appeals filed in good faith but ultimately unsuccessful do not, in themselves, become triggers for further enforcement. The merchant retains the right to pursue subsequent appeals or external escalation through LAPS SJK or OJK.

For matters involving suspected criminal conduct, regulator instruction, or sanctions enforcement, the appeal process described in this section runs in parallel with, not in place of, the formal regulatory or legal process; the AMLCO clarifies the interaction in the appeal response.

6. Account closure

Where investigation supports closure rather than reinstatement, the merchant relationship is terminated under the Service Agreement termination clause. After closure:

  • API credentials are disabled.
  • Pending settlements are reconciled; remaining funds (after fees, chargeback liability, refund obligations, and any regulator hold) are returned to the merchant's nominated bank account on file within 90 days.
  • The merchant cabinet remains accessible in read-only mode for 12 months, allowing download of historical transaction records.
  • Outstanding obligations owed to UnitPay survive closure and are pursued through ordinary legal channels.
  • Webhooks and API integrations stop firing immediately so that downstream systems do not continue to assume a live relationship.
  • Customer-facing payment widgets served from UnitPay endpoints stop loading; merchants are advised to remove the widget from their checkout in advance to avoid customer confusion.

Where the closure is initiated by the merchant rather than by UnitPay, the same procedural steps apply, but the timeline for fund return is the standard 30-day notice period set out in the Service Agreement plus any chargeback-tail reserve.

Merchants may export their full transaction history and KYC artefacts (where retained on the merchant side rather than on the data-subject side) before the read-only window closes. After the read-only window expires, the merchant cabinet is fully de-provisioned and access can no longer be restored.

7. Data retention after closure

KYC documentation, transaction records, AML case files, and related materials are retained after account closure for the periods specified by Indonesian law and regulation: five years for KYC and AML records (UU TPPU Article 21), seven years for transaction-level records (Bank Indonesia audit), and longer where specific regulatory or legal-process requirements apply. The full retention schedule and lawful bases are documented in our UU PDP Personal Data Notice.

During the retention window, identifying personal data is access-restricted to compliance and legal staff with named-individual approval. Operational read access is removed, so post-closure data is not visible to merchant-cabinet operators or routine support staff.

Data subject rights remain exercisable after account closure, subject to the regulatory retention obligations described above. Requests are directed to dpo@unitpay.net.

After the retention period elapses, records are deleted on the next scheduled deletion cycle. Where law requires longer retention than the standard schedule (for example, an active investigation), the extension is documented with the underlying lawful basis in the case file.

For questions about a specific suspended or closed account, the merchant or its authorised representative should write to legal@unitpay.net citing the merchant identifier. The Legal team coordinates with Compliance and Operations to provide a coordinated response within the timelines applicable to the underlying matter.

Where this Blocking Rules page conflicts with the binding Service Agreement signed between UnitPay and a specific merchant, the Service Agreement controls. This page is the public-facing description of our standard practice; bespoke variations are recorded in the Service Agreement.

Effective date: 06 May 2026