[permafrost]

[ QUOTE ]
all the statute says is that the Fed must draft regulations

[/ QUOTE ]

Actually, the Treasury Dept. Secretary, the Federal reserve, and the Attorney General will prescribe regulations.

Those regulations would not apply to Neteller (or a US bank's dealings with Neteller) unless Neteller volunteers to follow them, which they say will happen (worried about aiding and abetting?). I don't think the regulations of 5364 can be written to prevent anything more than a 'restricted' transaction.