[JPFisher55]

Basically, banks only have to adopt policies to identify and block restricted transactions in which the bank is the first US bank involved in the transaction. This includes the first US bank to handle an ACH from a foreign bank or from a customer. Transactions in which the bank is an intermediary are exempt. Checks seem to receive similar treatment. Bank cards are treated much harder because of coding, but most of them are currently blocked anyway.
Problem is that no instruction, list or definition is provided to define unlawful internet gambling. Thus, a bank cannot know what a restricted transaction means. But some of the examples suggest that a bank can meet the regulation by contract terms with customers and foreign banks that the customer or foreign bank not originate or receive a restricted transaction (whatever that is).
I'm not sure that these regulations will make much difference.