I think Neteller and other services can be affected.
Sec 801.5362. Definitions
3. DESIGNATED PAYMENT SYSTEM. The ‘designated payment system’ means any system utilized by a financial transaction provider that the Secretary and the Board of Govenors of the Federal Reserve System, in consultation with the Attorney General, jointly determine, by regulation or order, could be utilized with or to facilitate, any restricted transation.
This could certainly ban electronic wallet transactions with certain vendors or outside the US, it sounds like to me. Definition 4 details what “financial transaction provider” is they identify “stored value system”, “money transmitting service”, and “designated payment system”
So, western union, neteller, etc could all be affected, as could the
“operator of a terminal at which an electronic fund transfer may be initiated.
That sounds like tellers and guys who have western union at the liquor store, are all included in this law.
The good news is there is 9 months before it starts and it may be a difficult task to stop everything right off. Best of all, nothing that directly affects the advertising model that we work under.