There is a thought experiment I return to whenever I'm trying to explain why the debanking of legitimate businesses is a structural problem, not just a customer service failure. Imagine that a national electricity supplier decided, on a commercial risk basis, that manufacturing companies in a particular sector — say, chemical processing — were too operationally complex to serve. Not because those companies were doing anything illegal. Not because they had failed to pay their bills. But because the supplier's risk team had decided that the sector carried reputational exposure, and it was simpler to exclude it than to develop the capability to serve it properly. The electricity supplier refuses service. The chemical plants go dark.
We would not accept this. We would recognise immediately that electricity is infrastructure — that society has made a collective decision that certain services are essential to economic participation, and that the entities providing those services cannot withhold them on the basis of commercial preference alone. We regulate utilities as public services with access obligations, not as purely private businesses free to choose their customers. The electricity supplier must serve qualifying customers unless it can demonstrate a specific, documented reason not to.
Banking is infrastructure in exactly the same sense. And the fact that we don't yet fully treat it as such is the root cause of the debanking crisis that has been slowly building for a decade.
What Makes Something Infrastructure
Infrastructure has specific characteristics that distinguish it from ordinary commercial services. It is essential — participation in economic life requires it. It is provided by a concentrated market with high barriers to entry — the alternative to accepting service from one of a small number of providers is, effectively, no service at all. Refusal of service causes harm that is disproportionate to any individual provider's commercial interest in declining — the harm to the business refused falls entirely on that business, while the provider merely loses a customer.
Payment infrastructure meets all three criteria. A business without access to banking cannot receive revenue, pay employees, or meet its tax obligations. The UK banking market is concentrated in five major institutions that collectively control access to the payment systems on which commerce runs. And the harm of debanking — which typically means forced liquidation, loss of employment, and destruction of legitimate shareholder value — is catastrophically disproportionate to the inconvenience of the bank that declined the relationship.
The utilities analogy is not perfect. Electricity is fungible in a way that banking relationships are not. The AML framework requires financial institutions to make individual risk assessments that electricity suppliers are not required to make. There are legitimate reasons why a bank might decline a specific customer that have no direct equivalent in the utilities world. But these are differences of degree, not of principle. The core structural argument — that banking access is a prerequisite for economic participation, that the market is too concentrated to deliver access through competition alone, and that refusal causes disproportionate harm — holds regardless of those complications.
What the Utilities Model Actually Requires
The utilities model for banking doesn't mean every business has an absolute right to service from any institution it chooses. What it means, in practical terms, is a framework analogous to what we apply to utilities: a qualified right of access, combined with specific documented grounds on which service may be refused.
For electricity, those grounds are narrow — genuine safety hazards, debt, fraud. The supplier cannot refuse on grounds of commercial preference. For banking, the grounds need to be broader, because the AML framework imposes real obligations on financial institutions. But they should still be specific and documented: a particular business poses financial crime risk that the institution cannot manage, and here is the evidence for that assessment. Not: this sector category is too complex, or too reputationally sensitive, or not worth the compliance overhead at our institutional scale.
Several jurisdictions are moving in this direction. The EU's Payment Accounts Directive already provides a right of access to basic payment accounts for individuals, though not for businesses. The UK's Payment Account Termination Protection measures introduced in 2024 imposed some accountability for account closures. But both fall far short of a genuine infrastructure model — they deal in procedural requirements rather than substantive access obligations.
The Case for Going Further
The case for going further — for treating banking as regulated infrastructure with genuine access obligations for qualifying businesses — rests on two arguments that I find compelling. The first is the scale of harm. The businesses being debanked are not marginal operations. They are licensed iGaming operators, FCA-registered crypto exchanges, offshore holding companies serving legitimate investment structures. They are employing people, paying taxes, and operating within their regulatory frameworks. The harm of debanking at this scale is significant enough to warrant the policy response that other essential service failures have historically triggered.
The second is the failure of competition to solve the problem. The standard market solution to poor service is that competitors provide better service and win market share. This is not happening in complex business banking because the risk frameworks at every major institution are calibrated to the same de-risking logic. They have all made the same decision, simultaneously, to exit the same segments. Competition isn't producing better access — it's producing uniform exclusion. That is exactly the market structure that utility regulation is designed to address.
Where Payment Firms Fit
Payment firms like CCYFX are providing a partial solution in the absence of the regulatory solution. We have built genuine capability to serve complex businesses that the banking system has abandoned. That matters and it helps. But it doesn't resolve the underlying infrastructure problem, because specialist EMIs don't have access to the full range of banking services that complex businesses need — we can't provide trade finance, credit facilities, or the range of currency management services that a relationship bank could provide if it chose to engage properly.
The full solution requires the banking system to re-engage with complex business, under a regulatory framework that makes the cost of exclusion visible and the obligations of access clear. Payment firms are filling a gap. The gap shouldn't exist in the first place. Banking is infrastructure. It's time the regulatory framework reflected that reality.
CCYFX provides specialist banking infrastructure for complex businesses — iGaming, crypto, FX brokers, and offshore structures. UK, European & US IBANs. T+0 settlement.
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