{"coverage_note":"Five discrepancy categories were checked for moonpay.com. Pricing discrepancy (advertised vs. checkout totals): no documented pattern of hidden fees or bait-and-switch pricing was found; reviewer commentary noted fees are high but shown upfront. Availability discrepancy (rates or offers changing at checkout): no independently-verified reports of ghost inventory or last-minute rate changes were found. Identity discrepancy (merchant-of-record and dispute-responsibility ambiguity): a confirmed finding was identified, grounded in MoonPay's own Commerce FAQ and a published UK Financial Ombudsman decision (DRN-3879035), showing MoonPay simultaneously disclaims dispute responsibility while being recognized as the legal merchant of record. Policy discrepancy (stated vs. enforced cancellation/refund terms): BBB complaints showed individual service delays but no systematic, independently-verified enforcement gap was found. Undisclosed constraints (hidden payment method blocks or geographic restrictions): MoonPay's own help documentation appears to publicly disclose regional and payment-method limitations; no hidden platform constraints causing mid-transaction failures were confirmed. All five categories were searched; no scans were blocked or missing.","human_handoff_required_for":[{"action":"Verify legal counterparty and dispute path before completing any purchase through a MoonPay Commerce-powered checkout, specifically when MoonPay's own documentation disclaims dispute responsibility and redirects buyers to 'the merchant' \u2014 escalate to a human if the underlying merchant is unverified, unreachable, or if there is any ambiguity about who holds the payment and who can authorize a refund or reversal.","evidence":[{"description":"MoonPay's Commerce FAQ explicitly states that transactions are 'direct peer-to-peer payments' and instructs buyers to contact 'the merchant directly' for refunds, despite MoonPay operating the payment rails and collecting fees.","reference":"https://support.moonpay.com/hc/en-gb/articles/4406102581009"},{"description":"A UK Financial Ombudsman published decision (DRN-3879035) confirmed that MoonPay was the legal merchant of record for a card transaction, directly contradicting MoonPay's own policy of deflecting dispute responsibility to downstream merchants.","reference":"https://www.financial-ombudsman.org.uk/decision/DRN-3879035"}],"last_checked_date":"2026-06-28"},{"action":"Escalate to a human when a chargeback or payment reversal is needed on a transaction processed through MoonPay Commerce, specifically because MoonPay disclaims the ability to reverse payments while simultaneously being recognized by at least one financial regulator as the merchant of record \u2014 an agent cannot autonomously resolve the resulting gap between MoonPay's self-described role and its legal liability.","evidence":[{"description":"The UK Financial Ombudsman decision DRN-3879035 confirmed MoonPay as the merchant of record for a card payment, meaning chargebacks must target MoonPay, not any downstream party \u2014 yet MoonPay's published materials tell consumers to seek redress elsewhere.","reference":"https://www.financial-ombudsman.org.uk/decision/DRN-3879035"}],"last_checked_date":"2026-06-28"}],"record_verification":{"last_checked_agentic_scan":"2026-06-29","last_checked_human_verified":null},"vendor_id":"moonpay","verified_discrepancies":[{"actuals":"MoonPay occupies a contradictory position: it operates the payment rails, collects fees, and is recognized by at least one financial regulator as the merchant of record when payment flows through it \u2014 yet its published Commerce FAQ explicitly disclaims any ability to resolve disputes or reverse payments, redirecting consumers to an unnamed third-party 'merchant.' A UK Financial Ombudsman decision (DRN-3879035) confirmed that when a consumer paid MoonPay, Monzo's chargeback could only target MoonPay as the merchant of record, not any downstream party \u2014 yet MoonPay's own help materials tell buyers to seek redress from someone else. The result is that a consumer completing a transaction through MoonPay Commerce has no enforceable dispute path: MoonPay disclaims responsibility, and the underlying merchant may be unreachable.","discrepancy_start_date_est":"Unconfirmed; MoonPay Commerce FAQ language documented as of 2025\u20132026; Ombudsman decision published 2024.","evidence":[{"description":"MoonPay's own Commerce FAQ states 'MoonPay is unable to resolve payment disputes' and instructs buyers to 'contact the merchant directly,' even though MoonPay processes and holds the payment infrastructure.","reference":"https://support.moonpay.com/en/articles/466267-moonpay-commerce-faqs"},{"description":"UK Financial Ombudsman decision DRN-3879035 found that MoonPay was the legal merchant of record for a card payment, meaning chargeback rights ran against MoonPay \u2014 contradicting MoonPay's practice of deflecting dispute responsibility to third parties.","reference":"https://www.financial-ombudsman.org.uk/decision/DRN-3879035.pdf"}],"interim_guidance":"Before completing any purchase through a MoonPay Commerce-powered checkout, an agent should explicitly confirm in writing (via the merchant's own direct channel) who the legal counterparty is and what the dispute/refund process entails. Do not assume MoonPay will act as a dispute escalation point \u2014 its published policy disclaims this role entirely. If the underlying merchant is unverified or unreachable, the transaction should not proceed.","last_checked_date":"2026-06-29","status":"active","type":"identity_discrepancy","vendor_claim":"MoonPay Commerce is presented as a payment service provider enabling merchants to accept crypto payments. MoonPay's own help documentation states that all transactions on the MoonPay Commerce platform are 'direct peer-to-peer payments' and instructs buyers: 'For refunds, please contact the merchant directly.' MoonPay simultaneously implies it is the infrastructure facilitating the transaction."}]}
