First, models are not employees. Since you aren't hiring them, there's no issue of discrimination because they are not entitled to equal opportunity protection. They are contractors, not employees. Unless you're a government organization, a business owner (i.e., a contractor, in other words, a model) has no rights for "equal treatment" in procurement; a company is free to choose the company they wish to do business with.

Second, every employer discriminates every day. If you advertise for a PHP programmer, and the guy who shows up can't decipher the simplest line of code, he isn't qualified, and you are discriminating, rightfully and legally, by choosing to only hire someone qualified for the position you are seeking to fill. Even if you were hiring models as employees, if the model's "looks" are a bona fide part of the qualifications for the job (and clearly they are) then you can absolutely choose not to hire them if they do not meet your criteria - as long as that criteria is consistent among everyone who applies.

Boyfunk has had some youthful looking 18 and 19 year olds that have worked for us, and many of the models on our site are young looking. One of the reasons that we have so far avoided buying content from other producers is we cannot absolutely ensure that any content we buy is legal. Given the Brent Corrigan matter, it would be entirely possible for an unethical photographer (or model) to provide faked IDs, to shoot the model months before their 18th birthday and then fake the production date to be after the model turned 18, or the like. By shooting our own content, we are in the position of being able to physically examine the ID documents of all of our models, check them against the ID verification book we use, compare the signature of the model with the signature on the ID, and other things to take every reasonable precaution to ensure the model is of age.

In that way, we can perhaps provide a higher level of assurance to our affiliates that we have personally inspected and verified the ID documents and ages of all of our models to the best of the abilities we have.

That of course won't stop Visa or an IPSP or merchant provider from questioning us and asking to see the IDs, and we can also understand that the combination of youthful models and suggestive language may cause problems in compliance.

At the end of the day, I applaud both Epoch and CCBill for their stance on this; let's not forget that Neova did not do this, and it's clear where it landed Aaron as a result. Likewise, I would suspect that some of the smaller companies that are processing for the questionable Russian sites may find themselves having problems with Visa down the road.

For my money, a conservative but reasonable approach to underwriting and compliance is definitely the way to go. It may annoy me momentarily, but ultimately it benefits all of us if it ensures that the processors will be around in the long term.