[AverageJoe]

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WRONG!
The bargaining chip is forcing the DOJ to take the legally inconsistant position that Neteller is required to transfer funds which the DOJ says Neteller conspired to break the law by transferring in and out of prohibited gambling sites.

This is what I would be advising Neteller to do. Make the DOJ either be the heavy here with millions of Americans'smoney and (Billions of Dollars?), make the DOJ take a legally inconsistant position that may cripple their prosecutions, or get them to grant immunity for Neteller if they will return the money and agree not to conduct this business in the US again.

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DOJ will never request “transfer from poker site to player,” but might find a way to charge NT with taking illegal possession of the players’ money, and lying about being unable to pay. By the way, even if their untrue statements are not directed at the Feds, but the Feds read them in the course of their investigation, they are lying to the Feds, which is a separate crime, because they should know that the Feds might read them.

From the DOJ point of view facilitating Internet gambling is a crime. Your “they agree not enter the US market again” means “If you ignore our past crime we promise not to commit that crime in the future.” Things just do not work that way.