Scrubbing the fault of processors or merchant banks?
 

I am wondering if scrubbing is really in the hands of processors or the merchant banks when the transactions are posted

likely each processor has their own blacklists, but after that, randomly declining transactions doesn't make sense

both

the gateway processor usually have their own fraud controls in place to top of the banks

Processing isn't quite as cut and dry as that, Doug. While alot of processors use a negative database as their decline base, many of them, like CCBill or gateways using ProfileCheck, for instance, also use a scoring system, which is similar to say, a credit loan application. Then you also factor in things like CVV2 to finalize the scrub authorization or decline.

Acquiring AND issuing banks may also have their own reasons for turning down a transaction, based on their own criteria that revolves around the cardholders spending habits or the banks own internal rule system.

something is fucked up wherever it's being done