Merchant Application Underwriter (High-Risk)

Job Description

About Paynote\n

Paynote is a PayFac Merchant of Record that serves merchants most processors turn away. Our focus is high-risk businesses, including verticals that sit on bank restricted lists including but not limited to Nutraceuticals, Telehealth, Vapes/Nicotine products, Sweepstakes and skill games, subscriptions, etc...

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As merchant of record, we take full liability for every account we approve. That is why we only work with good operators, and why the person who decides who gets in matters more here than almost anywhere else in payments.

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The Role\n

We are hiring a Merchant Application Underwriter to own the front door: every new merchant application, from first submission to approve, decline or conditional approval.

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This is a pre-boarding underwriting role. You decide whether a merchant should be onboarded at all, based on who the owners are, whether the business is real, and whether the model is one we can stand behind with our own balance sheet. It is not credit review, risk review or portfolio monitoring of accounts that are already live.

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You will work in verticals that most banks and processors will not touch, so you need to know how these businesses actually operate, what a good one looks like, and how a bad one disguises itself.

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What You'll Do\n

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• Underwrite new merchant applications end to end and make a clear approve, decline or conditional-approve call, with a written rationale that holds up later.
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• Run KYC and KYB on the entity, beneficial owners and control persons, including ownership structure, prior entities, and adverse media and sanctions screening.
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• Validate that the business is real: website and product, domain age and history, social presence, supplier and fulfillment arrangements, licensing, and whether the stated model matches what the site actually does.
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• Review processing statements, bank statements, financials and prior MATCH or terminated-merchant history, and test them for consistency against the stated volume, ticket size and model.
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• Assess vertical-specific risk: chargeback exposure, refund policy, delivery timelines, advertising and marketing practices, regulatory exposure, and licensing requirements.
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• Set the terms for approved merchants, including volume caps, reserves, settlement timing and conditions, in coordination with our leadership and compliance team.
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• Detect and escalate fraud, including synthetic identities, fabricated documents, front companies and straw owners.
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• Engage directly with applicants and sales partners to request information, clarify gaps and explain decisions.
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• Document decisions and feed what you learn back into our underwriting policy, checklists and vertical playbooks.
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What We're Looking For\n

The non-negotiable is direct, hands-on experience underwriting merchant applications at the point of onboarding, in high-risk payments.

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• Recent experience underwriting new merchant applications for an acquirer, ISO, PayFac, high-risk processor or payment facilitator. You were the person who approved or declined the application, not the person who reviewed the account six months later.
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• Real experience in high-risk and bank-restricted verticals. Examples include nutraceuticals and supplements, CBD and hemp, nicotine and vape, adult, online gaming and sweepstakes, travel, subscription and continuity billing, debt and credit services, telehealth, firearms and accessories, crypto, and lead generation. You do not need all of them, but you should be able to speak in detail about the ones you know.
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• A working knowledge of card network rules and monitoring programs, including chargeback and fraud thresholds, MATCH, and how acquirer and bank restrictions shape what we can approve.
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• Strong KYC and KYB skills, including tracing beneficial ownership, spotting shell structures and recognizing nominee owners.
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• Sound commercial judgment. You can tell a good operator in a difficult vertical from a bad one, and you can explain the difference in writing.
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• Clear written communication. Your decision notes should be short, specific and defensible.
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• Comfort making decisions with incomplete information and owning them.
  
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Fluency With Modern, AI-Enabled Fraud\n

The applicants we see are increasingly sophisticated, and many now use AI to manufacture a convincing paper trail. We need an underwriter whose instincts and methods are current, not built for a world where a forged document took effort.

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You should be able to show how you would catch:

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• AI-generated or edited documents, such as bank statements, processing statements, incorporation papers, IDs, utility bills and invoices, including tells that go beyond visual inspection (metadata, font and layout inconsistencies, math that does not reconcile, and statements that do not match the bank's real format).
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• Synthetic and stolen identities, deepfaked or injected selfie and liveness checks, and voice or video impersonation on verification calls.
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• Fabricated businesses: websites generated in hours, cloned storefronts, fake reviews and social proof, newly registered domains, and fictitious suppliers or customers.
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• Nominee or straw owners fronting for a terminated or MATCH-listed principal, and applicants resubmitting under new entities, new names and new addresses.
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You are comfortable using modern tools to do this, such as document forensics, identity and liveness verification, web and domain intelligence, and AI-assisted analysis, and you are curious about where the next technique will come from. You treat verification as a process of independent corroboration, not a check of whether something looks right.

Nice to Have\n

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• Based in Miami and able to work from our office. This is a strong plus, though we will consider remote candidates.
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• Prior experience at a PayFac, high-risk ISO or merchant-of-record business, where you carried real accountability for approvals.
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• Familiarity with underwriting and onboarding platforms, sanctions and adverse media tools, and identity and document verification vendors.
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• Experience building or improving underwriting policies, vertical playbooks or checklists.
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• Relevant certifications, such as CAMS, CFE or ACFE membership, or Certified Payments Professional credentials.
  
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What This Role Is Not\n

Please read this before applying. This role is a poor fit if your experience is mainly in:

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• Risk review or credit review of merchants that are already boarded.
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• Portfolio monitoring, transaction monitoring or chargeback management.
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• Compliance or BSA/AML program administration without hands-on decisioning on applications.
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• Back-office onboarding support, where applications are collected and checked for completeness but someone else makes the decision.
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If you have done some of these alongside real application underwriting, tell us which part of your time went where.

Location and Schedule\n

This role is remote. We expect you to be available and responsive from 9:00 am to 5:00 pm Eastern Time, Monday through Friday, because applicants and partners are waiting on decisions during those hours.

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• We would especially like to hear from candidates in Miami who can work from our office, but you do not need to live there to be considered.
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