I digress. Patricia, I am not sure if you agree or disagree with the article. Either way, here is some reading which shows the “legal” online gambling is a bit scared from the regulations (emphasis mine):
American Greyhound Track Operators Association:
Under Section 5(a) of the Proposed Regulation, participants in designated non-exempt payment systems (which includes financial transaction providers) can (l) simply rely on established written policies and procedures of the payment systems which are reasonably designed to identifY, block, and otherwise prevent restricted transactions; or (2) establish and comply with their own written policies and procedures that are reasonably designed to accomplish the same thing. In other words, the Administration causes participants to create policies to block illegal transactions but does not encourage the financial institutions to additionally create policies to permit legal transactions, such as those in the pari-mutuel industry.
When presented with a choice of processing legal pari-mutuel transactions in the face of an ambiguous regulation, payment processors will, in all likelihood, avoid processing any transaction and could block legal transactions. During the comment period ofthe Proposed Regulations, many financial institutions noted that the over-blocking provisions would allow them to block all transactions regardless oftheir legality. For example, the Kansas Bankers Association stated that the over-blocking provisions permit “institutions to decide to completely avoid processing any gambling transactions and thereby avoid the potential liability presented by this proposal.”
Full comments here: http://www.whitehouse.gov/omb/oira/1505/meetings/813-1.pdf
Small Business Administration: Office of Advocacy (2007)
The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits this comment to the proposed rulemaking on the Prohibition on Funding of Unlawful Internet Gambling. The Office of Advocacy believes that Department of Treasury and the Federal Reserve System (hereinafter “the agencies”) have not analyzed properly the full economic impact ofthe proposal on small entities as required by the Regulatory Flexibility Act (RFA). Advocacy recommends that the agencies prepare a revised initial regulatory flexibility analysis (IRFA) to address the concerns presented below.
Full letter here: http://www.whitehouse.gov/omb/oira/1505/meetings/813-4.pdf