Let me further elaborate:
Consumer accounts are not specifically exempted – rather, “commercial accounts” are being targeted and procedures only need be applied to commercial accounts.
This does not preclude the possibility that a consumer account can be used for commercial purposes. A consumer account is not specifically exempted – just not within the requirements.
The law always has a gray area – and this is clearly gray. You wouldn’t be targeted if you were making a deposit or receving winnings, or even affiliate earnings – but if your account was thought to be processing transactions, rightly or wrongly, a bank may determine that your account is being used for commercial purposes and thus apply the law according to its own interpretation.
Maybe it’s a question of semantics. “Exempt” to me means specifically excluded. I do not believe that, under this definition, a personal or consumer account is automatically exempt.