> we fell outside of their "risk appetite."

If you take that statement at face value (not sure if you should), it's fascinating to think that your business was able to operate for two decades with what I assume are the standard problems people in the porn industry face (e.g. chargebacks from customers unwilling to admit they subscribed in their SO's presence and so pretending it was a scam, etc.)

And yet seemingly none of the bank's risk heuristics based on actual transaction profiling ever went off.

Wouldn't that mean that, in practice, being in the porn industry isn't as high-risk as banks / payment processors think it is?

And would this not then suggest a gap in the market, for an (ideally vertically-integrated) bank + payment processor + card issuer + KYC provider, who is willing to

1. evaluate risk on a customer-by-customer basis (through e.g. continuous dynamic network analysis of transaction flow, with txs annotated with their KYC info) rather than by actuarial categorization; and

2. avoid seeking any investment (at any remove) by parties who would insist they avoid these types of customers?

The risk they're talking about is risk of government interest in them, which is never cheap when you run a business.