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Why the Next Wave of Banking Deplatforming Will Hit Complex Businesses Hardest — And What You Can Do Now

Over the past eighteen months, we have seen an unprecedented acceleration in what I would characterise as structured deplatforming: the systematic withdrawal of banking services from entire business categories, not for compliance failures, but for classification risk. Correspondent banks are tightening exposure thresholds. Tier-1 clearing banks are quietly offboarding client segments they once embraced. And the businesses most exposed are not the bad actors — they have been gone for years. The businesses being squeezed now are the legitimate, licensed, regulated operators who simply operate in sectors that have become too commercially inconvenient to support.

What is driving this? The answer lies at the intersection of Basel III capital treatment for operational risk, the expanding scope of de-risking guidance from the Financial Action Task Force, and a fundamental misalignment in how large banks calculate the cost of compliance versus the revenue generated by complex-sector clients. When a correspondent banking relationship requires enhanced due diligence, ongoing monitoring, and dedicated compliance resource, the economics only work at scale. Mid-market operators with turnover below £50M find themselves priced out — or simply declined — with no meaningful explanation and no formal right of recourse.

The FX dimension of this problem is often underestimated. Businesses that lose their primary banking relationship do not just lose a payment account — they lose their FX conversion infrastructure, their forward hedging facilities, and frequently their ability to manage multi-currency treasury positions with any degree of efficiency. We have onboarded clients who were converting currency at 2.8% over mid-market through emergency payment providers because their bank had gone. That is not a compliance cost. That is a structural tax on being complex.

The answer is not to camouflage your business model or restructure your corporate hierarchy to look simpler than it is. The answer is to find infrastructure that was built specifically for what you are. CCYFX was created for this reason: to provide specialist payment and FX infrastructure to businesses that deserve it but cannot access it through conventional channels. In this letter, I want to explain what we are seeing in the market, what we think comes next, and what the practical steps are for an operator who wants to build financial infrastructure that is resilient to the next wave of deplatforming.