working my way through it (just finished the 30 page preamble); it seems to have been a complete punt by the Treasury (and Fed Board) on the issue; the proposed regs apparently just call for banks and other finacial institutions to implement appropriate policies and procedures to prevent money being transfered to foreign gambling companies. This is nothing new....the act already called for that, the regs were supposed to specifiy how this might be done and that doesn't appear to be what happened. The proposed regs also provide specific expemptions for the financial middlemen and orginiating banks (i.e., the gambler's bank and the clearing houses) for ACH, Checks, and Wires and puts the entire enforcement on the financial instution that would have a customer relationship with the gambling company (with a provision that tries to get at cases where this relationship is indirect).
Anyway, not much there, probably the best we could have hoped for - but this is just my first impression, I am going to read the actual regs themselves now (the preamble just explained what they were trying to do and areas where they are specifically asking for comments).
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