PPA has released its UIGEA regulations comment talking points

[JPFisher55]

Skall, if you remember my proposed definition, it did exactly what you stated. It defined UIG as sportsbetting, except horse racing and fantasy sports, and any other online gambling that is expressly banned by state statute.
I doubt that the regulators will accept any definition because they want overblocking. I think that US banks will find that overblocking will cost them lots of customers, problems with correspondent foreign banks and money. They may just decide to ignore the regs because they are pretty toothless.
However, if WTO doesn't force the hand of the DEMS in Congress, the iMEGA loses and Kaplan loses, then litigation will result. I think that you have a year to prepare.