NO doubt various interests are present. This is something I also find iteresting, another comment submited to the Whitehouse OMB, this one by the Kansas Bankers Association:
Monitoring. We agree with the conclusion of the proposed rule that with regard to ACH systems, check collection systems, and wire tranfer systems, there is no capability to monitor payment patterns, unlike what might exist for other types of payment systems. It is clear from the proposal, that should technology develop that would allow such monitoring, the rule could be amended to reflect this.
I guess they have already raised the white flag on the ACH/Check/Wire, all it’s left I guess is credit cards and debit cards, for which online gambling websites use third party non-gambling processors, unlike horse and dog, who likely use in-house clearing systems.
Also:
List of Unlawful Internet Gambling Businesses. The proposal suggests that perhaps a list of businesses conducting unlawful intemet gambling could be maintained and that participants would then have an obligation to routinely check the list before opening an account. We believe that while having such a list would make compliance with this proposal much easier, we also believe that maintaining such a list so that the information was up-to-date and accurate would be impossible. There are mOre entities out there who would want to deceive the gatherer of that information than would gladly give accurate information. Maintaining its accuracy would be more than a full-time job with much time and many hours devoted to investigation of information.
Yeah, liek they are not cutting jobs already.
Although Kansas banks would love to get a hold of the money of the offshore gambling websites:
The proposal requests comment on the appropriateness of the examples given of a participant’s responses upon learning that a customer is engaging in restricted transactions. We believe that the examples accomplish the stated goals and are appropriate responses to a discovery that a customer is engaging in restricted transactions. We would offer one additional suggestion, that financial institutions ‘be authorized to initiate a freeze of the funds in the account until processing for fines can be implemented.