I don’t believe it’s going to take any real creativity for affiliates to be paid and deposit earned funds. This bill was not designed to stop gambling (lotteries, horse racing, land based casinos etc). It is strictly to prevent the outflow of a huge amount of money that no taxes are collected from. Lets say you own gobs of money casino (I use that because hopefully it doesn’t exist lol) and you set up an account to pay affiliates under a different name that doesn’t collect any funds, only pays them out. I don’t think there would be any problems because governments love incoming funds. All they would want is for it to not be obvious because that would allow the public to see the real reason for the bans.
As for click2pay, yeah they phone you before you can use your account for verification. But if you can’t even get to that point then this will not be an option for gambling sites either. Which means they will end up recommending someone else. Maybe a new one that doesn’t even exist yet so I would sit tight and see what’s gunna come out of the wash.