[permafrost]

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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.

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You got the idea. Here's an "example"(1 of many)

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(b) Automated clearing house system examples.
(1) Except as provided in paragraphs (b)(2) and (b)(3) of this section, the policies
and procedures of the originating depository financial institution and any
third-party sender in an ACH debit transaction, and the receiving depository
financial institution in an ACH credit transaction, are deemed to be reasonably
designed to prevent or prohibit restricted transactions if they —
(i) Address methods for conducting due diligence in establishing or
maintaining a customer relationship designed to ensure that the customer
will not originate restricted transactions as ACH debit transactions or
receive restricted transactions as ACH credit transactions through the
customer relationship, such as –
(A) Screening potential commercial customers to ascertain the nature of
their business; and
(B) Including as a term of the commercial customer agreement that the
customer may not engage in restricted transactions; and

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