As a beneficiary's bank under a wire system such as FedWire or SWIFT you are expected to have a program in place that is reasonably designed to block or otherwise prevent your customer from receiving a wire transfer that is a restricted transaction.
There is no way for you, as the beneficiary's bank, to know the purpose of an incoming wire. Therefore your reasonably designed program has to focus on preventing a commercial customer from accessing incoming wire transfers. The procedures for such a program would ordinarily consist of a series of customer due diligence vetting questions used to determine whether a prospective commercial customer will be engaged in the business of Internet gambling, and, if yes (and if the bank wants to pursue the account relationship further), whether that Internet gambling business is legal (licensed). Put more simply, your procedure would be designed to prevent the bank from accepting as a customer a commercial enterprise that might operate an illegal Internet gambling business.
I'll be re-presenting my "Blocking Internet Gambling -- Are You Ready?" webinar on November 19. You should see a link to the program information to the left of these Threads.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8