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Over ten years ago, the Obama Administration introduced “Operation Choke Point,” a program that used the concept of “reputational risk” to encourage banks and similar financial entities to reevaluate providing services to customers connected to “heightened risk” transactions and crime. Merchant categories “that have been associated with high-risk activity” and named specifically in a Federal Deposit Insurance Corporation (FDIC) publication were telemarketing, online gambling, “racist materials,” Ponzi schemes, pornography, and dating and escort services, but also, extensively regulated and legitimate firearm and ammunition dealers.

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