Newnd - The policy posted on BOL was a generous peer contribution, not a model developed by BOL or its personnel. Its highest and best use is to help a bank get started on its own policy development; it is not a document that any bank could adopt without its own competent, critical review.
I have not read the policy, but agree that your policy should indicate your plans to block transactions in the way that the reg envisions; i.e. by conducting due diligence at account inception, not by interdicting transactions in process. The supplementary information accompanying the regulation acknowledges it is nearly impossible to block transactions in process and your policy should not reflect any general commitment to do so.
zitch70 - Due diligence could equate to: Is your organization in any way involved in gambling activities? A "yes" response means you go to enhanced due diligence; i.e. you determine what those gambling activities are. (They could be as innocuous as lottery ticket sales.)
Enhanced due diligence queries could continue with: Are any of your gambling activities conducted via the Internet? A "yes" answer would trigger further interrogatories designed to assure that the involvement was legal and would incorporate obtaining the documentation required by UIGEA.
Rosie O/Grady - The regulation's definitions lack the precision found in most consumer protection laws. It simply defines commercial customers as non consumer customers; i.e. any customer that is not a natural person. Estates, trusts, etc. are obviously not natural persons so they fit this regulation's definition of a commercial customer. Nevertheless, it's a tad ridiculous to consider their potential involvement in Internet gambling.
The bottom line is will your examiners expect you to have used some common sense in excluding some customers from your notice and due diligence requirements? I'm not willing to rely on that; I would not advise you to exclude them.
Potential posters - This thread has become sort of a dumping ground for Reg GG questions. As the deadline nears and questions are now following questions it is increasingly difficult to figure out "who's on first" and hard to respond. Hence, some questions are not being answered. If you have a question that is not a follow-up, I suggest you start your own thread with a specific heading.
If you are trying to figure out what you are supposed to do just by asking questions in the Threads at this point you're toast. BOL's Webinar is still available. Buy it.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.