[JPFisher55]

Ok I read the regulations. They are much shorter than the preamble. My gist of the regulations that really affect online poker players and online gamblers are the regulations that concern relationships with foreign senders or foreign banks.

For ACH transactions, this is regulation 6(b)(2)(i). It requires banks to establish policies and procedures with foreign senders to prevent the foreign sender from sending restricted ACH's. 6(d)(2)(i) does the same for checks. The other regulations concern what steps the banks must take when some customer or foreign sender receives or originates a restricted transaction.

So my question is what policy or procedure can identify a restricted transaction when the restricted transaction is not defined because it depends on the undefined term "unlawful internet gambling?" How can a foreign bank or sender know what is a restricited transaction?

Maybe we can comment that such policies and procedures cannot be implemented because it is not practical for a US bank, foreign bank or foreign sender to know what is a restricted transaction. This would further water down the regulations.

The regulations do require a bank to adopt policies and procedures with its commercial customers to insure that such commercial customers do not originate or receive restricted transactions. Could we comment that this is the only practical regulation for US banks? Or even simply require US banks not to have a direct relationship with any commercial customer in the internet gambling industry? I don't know of any businesses in the internet gambling industry that have a customer relationship with a US bank anyway.

IMO, what the regulations demonstrate is how unworkable the UIGEA actually is. Now I wonder if the iMEGA attack on the UIGEA is worth the effort. It's the Wire Act and some state laws that are the real problem.