[Wynton]

I have not yet read the regulations myself, and only skimmed this thread. But allow me to pose a question.

Do the proposed regulations really require the banks to make independent determinations of whether particular companies meet the definition of being engaged in illegal gambling operations? This process seems to entail two steps: (1) a factual investigation of what the company actually does; and (2) a legal analysis of whether such conduct violates the law.

These steps seem so beyond the capacity of the banks that it's hard for me to believe that we are not going to end up with a specific list - compiled and continually updated by the Treasury Department, regardless of any comments we may or may not make.