Best Canadian Casinos - UIGEA Implementation Rules Published
However, it may help if we would clarify a number of point which the report discusses. Firstly, the rules, as proposed, govern only those who are participants in the designated payments system or are a financial provider. An end-user or customer is not a participant, hence the rules do not apply. In other words, it is not illegal to gambler, but you will be stopped when you will have to make a transaction.
The report also makes the distinction that neither it, nor the UIGEA define what is illegal gambling. This is left to the existing state, federal, and tribal laws. Some restricted transactions will be exempt from regulation if the Agencies determine that "it is not reasonably practical to identify and block, or otherwise prevent or prohibit the acceptance of such transactions." For instance the proposed rules exempt all participants in the ACH (automated clearing house), check collection systems, and wire transfer systems, except the beneficiary's bank, or the bank acting on direct behalf of an illegal gambling business.
At this point in time, there will be no master list of unlawful internet gaming businesses. While the Agencies have stated some of the benefits to participants by creating such a list, they also cite the cost, accuracy issues, and liabilities associated with its creation. Just the time to accurately research and interpret all of the state, federal, and tribal gaming laws was cited as an impediment.
The specific process and procedures financial institutions were to follow to prevent restricted transactions, or what they should do when they came across one, was left somewhat vague. Clearly one of the biggest issues the banks will face is exactly how to determine if a transaction is restricted under the law or laws. If the Agencies felt the task too labor intensive, liability prone, and costly, to compile a list of illegal online gambling companies, how will the banks accomplish the task?