Wwft institutions must perform Customer Due Diligence (CDD) on their customers and their customers' UBOs, perform transaction monitoring (TM) over the business relationship with their customers and report unusual transactions to the authorities. When a card-acquirer provides payment services to a payment facilitator (PFac), it is debatable whether the PFac's merchants (Sub-Merchants) qualify as the card-acquirer's customers and business relations within the meaning of the Wwft, whether the card-acquirer has CDD and TM obligations on the Sub-Merchants, and if so, what the scope of those obligations is. This article seeks to examine this matter.