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Well I read it .

1. I don't see any rules that make it illegal for gambling sites to send money back to their customers.

2. I don't see any rules that make it illegal for Neteller and similar services to receive payments from (or make payments to) their account holders.

3. The rulemakers apparently have a duty under 5364(b)(4) to ensure that their rules don't result in blocking of legal transactions. That would seem to prevent rules that result in blocking deposits to Neteller and similar services.

4. Neteller and similar services obviously can't comply with the coming bank regulations so they may need to move completely offshore. Would that exempt them from our banking regulations if they continue to have U.S. account holders? Or do they become as illegal under U.S. law as the gambling sites they service? It's interesting to think of a hypothetical "real" European bank that happens to have a few U.S. customers with accounts linked to Party. What laws apply and how would they be enforced?

5. The internet access provision seems pretty harmless. They can force a service provider to take down an illegal gambling site operating on their servers. Like that would be the enforcement action of choice against someone caught running a site on U.S. soil . More seriously, they can attack U.S.-based affiliates by forcing removal of direct links to illegal overseas sites. But there seems to be no provision for removing text URLs that cannot be clicked. Probably a justified fear of First Amendment litigation on their part. So maybe we see circumventions like "type in www<dot>pokerfoo<dot>com and enter bonus code POKERFUN100".

6. It isn't easy or convenient for the government to force a computer service provider to do anything. They have to do all the research themselves and then be very specific about what they want which is tough when the offending web site may change its links in the middle of the process. There is even a provision for a hearing before the service provider has to remove offending material. Going after affiliate links may be pretty impractical.

Comments please .

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