This is not a particular problem at all in this case. The business in question is not a payment service provider at all, they only happen to process billings a

This is not a particular problem at all in this case. The business in question is not a payment service provider at all, they only happen to process billings and disbursements on behalf of third parties as a part of the service they provide to the end user, and only in certain cases. They have also been doing so for some time. This is a b2b scenario with no current need for credit card payments at all; its all wire xfer, chq, eft etc.