We have a couple of sample policies for unlawful Internet gambling, one of them is from BOL. On this it does describe due diligence & actual knowledge.

Is anyone doing more for monitoring purposes and if so what??

We use Jack Henry's Yellow Hammer BSA and did add a question for CDD-- regarding UIG--at account opening--JH said this was all we could do.

Thanks for any input.

We anticipate adding a question to CIP/CDD and sending the advisement to current commercial accounts. I don't anticipate that we will do more for monitoring purposes until I've had a chance to see what might be available. Do you know yet if Jack Henry's Yellow Hammer BSA actually has anything in it to monitor such activity?

There is a report that we have tried to run before from JH YH BSA and hasn't yet worked. We are contacting JH for help with this---the report pulls the NAICS code tied to gambling & casinos--I guess that's it as far as monitoring goes.

How detailed should the procedures be.

For example... if we receive notice that a customer has originated restricted debit transaction for ACH is simply okay to say the bank will terminate their access to the network and the account will be closed?

Does anyone have an example of the one time notice to commercial customers that were not subject to the UIGEA due diligence when they opened their account that they will be using? And can this be sent as a statement message? Thanks for anyone's help.

In the Operations thread, there are several discussions on this topic, and several posters have shared the veribage they are using.