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#1403387 - 06/14/10 07:25 PM
Reg GG
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Platinum Poster
Joined: Mar 2008
Posts: 808
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What was the verbiage that banks put in their statements regarding the one time notice for Reg GG? Now I am worried ours was not lenthly enough??
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#1404522 - 06/16/10 05:56 PM
Re: Reg GG
SUSANE1
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New Poster
Joined: Jun 2010
Posts: 15
Minnesota
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Our bank used this: "The Unlawful Internet Gambling Act of 2006 prohibits Bank Name from processing restricted transactions through your business account. Please see our website: www.yourbankwebsite.com for more information.” which then directed the customer's to our website for the full-length information.
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#1404529 - 06/16/10 05:59 PM
Re: Reg GG
Op_Lady28
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Georgia Plum
Unregistered
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Here's what we used
• "In accordance with the requirements of the Unlawful Internet Gambling Enforcement Act of 2006 and Regulation GG, this notification is to inform you that restricted transactions are prohibited from being processed through your account or relationship with our institution. Restricted transactions are transactions in which a person accepts credit, funds, instruments or other proceeds from another person in connection with unlawful Internet gambling."
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#1404559 - 06/16/10 06:55 PM
Re: Reg GG
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Gold Star
Joined: Feb 2010
Posts: 356
Middlesex Cty NJ
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Here's another
Regulation GG Unlawful Internet Gambling Enforcement Act (UIGEA) of 2006
The UIGEA, signed into law in 2006, prohibits any person engaged in the business of betting or wagering (as defined in the Act) from knowingly accepting payments in connection with the participation of another person in unlawful internet gambling. The Department of Treasury and the Federal Reserve Board have issued a joint final rule, Regulation GG, to implement this Act.
As defined in Regulation GG, unlawful internet gambling means to "place, receive or otherwise knowingly transmit a bet or wager by any means which involves the use, at least in part, of the internet where such bet or wager is unlawful under any applicable Federal or State law in the State or Tribal lands in which the bet or wager is initiated, received or otherwise made."
As a customer of XXX, these restricted transactions are prohibited from being processed through your account or banking relationship with us. If you do engage in an internet gambling business and open a new account with us, we will ask that you provide evidence of your legal capacity to do so.
_________________________
Lord,give me patience - and I want it NOW!!!
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#1406005 - 06/21/10 02:19 PM
Re: Reg GG
dickr
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100 Club
Joined: May 2010
Posts: 103
Arkansas
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We are late getting our notices out as we were in a change in compliance officers, so I stepped in. We want to do a statement stuffer, however, our processors cannot segregate personal accounts from commercial. We would have to stuff them manually which would cost more in postage, time, and man-power. Do you know if it would hurt to send the notice to everyone that way we can just send our stuffers to our processor to stuff?
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#1406017 - 06/21/10 02:29 PM
Re: Reg GG
sturner
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Georgia Plum
Unregistered
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I'd be looking for another processor if they can't do something as basic as separating personal from commercial accounts. There will always be things affecting one and not the other that you will need to notify of.
Can you do a statement message just for commercial accounts, rather than a 'stuffer'?
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#1406022 - 06/21/10 02:34 PM
Re: Reg GG
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100 Club
Joined: May 2010
Posts: 103
Arkansas
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Statement messages can only be 250 characters which includes spaces. It just wouldn't be enough room for anything really. I agree though....a processor should be able to segregate as many things do only affect certain accounts. It'd make things much more easier on us. Thanks!
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#1406108 - 06/21/10 04:11 PM
Re: Reg GG
sturner
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Georgia Plum
Unregistered
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We have the same space limitations and were able to get it on a statement message.
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#1421077 - 07/28/10 07:44 PM
Re: Reg GG
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Diamond Poster
Joined: Dec 2003
Posts: 1,382
Wisconsin
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Does Reg. GG only limit transactions from online gaming to electronic transactions? The reason I ask is that we have a customer who now has checks running through his account instead of debit card transactions, but from the same company as before. Should we be not paying and returning these checks?
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#1422477 - 07/30/10 09:56 PM
Re: Reg GG
CSB98
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Power Poster
Joined: Nov 2004
Posts: 6,925
Illinois
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Reg GG pertains to Commercial Customers processing the payments to then forward to funds to the online gambling sites. Your case sounds like a Consumer account where an individual has remotely created checks being presented.
This tells me that very likely, a Commercial Account has been opened wherever these checks have been deposited, and that business is most likely using a Remote Deposit Capture product to slide these checks through under the depository bank's nose. Although Reg GG does not require the drawee bank to monitor all of its inclearing checks (which would be impossible) since you have caught their existance in this one instance, you are within your rights to send your customer a letter stating that you will not honor any of these items going forward and close the account if they continue the activity.
You may also consider filing a SAR for the illegal activity. IF you are able, document the routing/account information from the back of the checks. This will provide law enforcement with a location to investigate the source of the checks.
Does your Reg GG Policy/Procedures address how you will handle the discovery of a consumer engaged in online gambling?
Last edited by crowman3; 07/30/10 09:59 PM. Reason: Follow-up question
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria! www.tcaregs.com
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#1422761 - 08/02/10 05:11 PM
Re: Reg GG
BrianC
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Diamond Poster
Joined: Dec 2003
Posts: 1,382
Wisconsin
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Our policy does mention that for consumer accounts we will monitor and block electronic transactions. I also think in this instance we will send a letter to the customer informing him we will not accept these transactions. Thanks for the input!
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#1422871 - 08/02/10 07:01 PM
Re: Reg GG
CSB98
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Georgia Plum
Unregistered
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Online gambling isn't all illegal. Reg GG only addresses 'illegal internet gambling'. Are the checks being deposited into his account, or debited out of his account? How do you know it is illegal gambling, has the customer admitted it? I would try contacting the BOFD and ask them what kind of business it is. It could be a legitimate gambling business, or not a gambling business at all. I think it deserves some more due diligence before you make a decision on what to do.
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#1422992 - 08/02/10 09:00 PM
Re: Reg GG
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Diamond Poster
Joined: Dec 2003
Posts: 1,382
Wisconsin
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So, how to you determine what's "illegal internet gambling" and what isn't? We've always worked under the guidelines that we wouldn't allow any electronic transctions to come through that were from any gambling sites. Not sure if this stemmed from something in the credit card guidelines or what?
The current checks are being debited from his account. The checks are being written out to PStars. This is what Poker Stars used to come through as on his debit card.
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#1423278 - 08/03/10 02:54 PM
Re: Reg GG
CSB98
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Georgia Plum
Unregistered
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Good question. And therein lies the dilemna. It really is the BOFD's problem if this is in fact an illegal internet gambling site since they are allowing the transactions to originate through them, that's why I suggested contacting them. They should know if it's a legal site or not, and if they are unaware of what their customer is doing, it's time for them to do some investigating. I'm not sure I would deny the transactions on your customer's account without some more information. JMHO.
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#1423295 - 08/03/10 03:08 PM
Re: Reg GG
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Power Poster
Joined: Oct 2009
Posts: 9,319
OK
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All of this is why there is proposed legislation to radically change, if not do away with, the UIGEA. The misunderstandings about this piece of legislation are enormous IMO.
_________________________
I'm fixin' to fix that.
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#1423299 - 08/03/10 03:13 PM
Re: Reg GG
raitchjay
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Power Poster
Joined: Oct 2009
Posts: 9,319
OK
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IMO, banks that are blocking Consumer gambling transactions are doing so on their own accord only (not that they can't). I don't believe they can point to the UIGEA and claim that they are forced to.
_________________________
I'm fixin' to fix that.
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#1423491 - 08/03/10 06:31 PM
Re: Reg GG
CSB98
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Georgia Plum
Unregistered
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Good question. And therein lies the dilemna. It really is the BOFD's problem if this is in fact an illegal internet gambling site since they are allowing the transactions to originate through them, that's why I suggested contacting them. They should know if it's a legal site or not, and if they are unaware of what their customer is doing, it's time for them to do some investigating. I'm not sure I would deny the transactions on your customer's account without some more information. JMHO.
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#1434633 - 08/26/10 03:48 PM
Re: Reg GG
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Gold Star
Joined: Nov 2005
Posts: 265
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The portion of Reg GG discussing money tranmitting businesses - is this talking about the bank being an MTB or servicing MTBs?
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#1436118 - 08/30/10 04:05 PM
Re: Reg GG
Sugarbaker
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Gold Star
Joined: Nov 2005
Posts: 265
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Does anyone know if we can omit the money transmitting business portion from our bank Reg GG policy or if we have to include it if since we may service a MTB?
Also, has anyone obtained a statement of compliance from pre-paid/gift card providers? We can't seem to get one from our vendor. What about if we take apps for VISA credit cards - do we need a statement from them too?
I have read the regulation, but this still isn't clear to me. Thanks.
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#1440469 - 09/08/10 11:33 PM
Re: Reg GG
Sugarbaker
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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I've voluntarily been monitoring offshore gambling sites (Pokerstars, Full Tilt Poker), then sending a letter to customers notifying them of Reg GG & stating if it continues, their Debit Card privileges will have to be canceled.
Can I quote Reg GG even though it technically is for Businesses & not consumers? What can I quote? If it's offshore & they're not offshore ... it is illegal.
_________________________
My opinions are my own, and not that of my employer.
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#1440515 - 09/09/10 10:12 AM
Re: Reg GG
WonderWoman
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Regulation GG is not in any way relevant to Internet gambling by consumers. Some gamblers would love to come in and confront your unsuspecting frontline personnel with that fact.
A correct statement would be: The U.S. Department of Justice considers such activity to be illegal and, on a number of occasions, has taken action against the individuals and banks involved by seizing funds.
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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.
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#1440574 - 09/09/10 01:28 PM
Re: Reg GG
SUSANE1
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Gold Star
Joined: Apr 2008
Posts: 475
NJ
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Existing customers were only required to get the one time reg GG notice and an annual notice is not required. Is this correct?
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#1440599 - 09/09/10 01:44 PM
Re: Reg GG
komply
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Power Poster
Joined: Aug 2002
Posts: 3,094
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That is correct.
_________________________
Opinions are my own and not of my employer.
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#1440601 - 09/09/10 01:44 PM
Re: Reg GG
ahou
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Gold Star
Joined: Apr 2008
Posts: 475
NJ
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Thnak you for the confirmation
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#1441883 - 09/13/10 02:43 PM
Re: Reg GG
komply
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Gold Star
Joined: Nov 2005
Posts: 265
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Bump -
Does anyone know if we can omit the money transmitting business portion from our bank Reg GG policy or if we have to include it if since we may service a MTB?
Also, has anyone obtained a statement of compliance from pre-paid/gift card providers? We can't seem to get one from our vendor. Is this something that we need/shoud be getting from them?
I have read the regulation, but this still isn't clear to me. Thanks. Top
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#1442288 - 09/13/10 09:45 PM
Re: Reg GG
komply
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Member
Joined: Dec 2007
Posts: 77
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Does anyone have a Reg. GG self-monitoring review checklist they would be willing to share for internal audit purposes? As of now I was just going to go off of the examination procedures, but thought I would ask the group.
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#1442343 - 09/14/10 12:32 PM
Re: Reg GG
RCRM
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100 Club
Joined: Jan 2008
Posts: 199
The Bluegrass
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I am in the middle of a Reg GG audit and have been using the exam procedures. I too have been looking for alternative checklist to use.
_________________________
CRCM
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#1446113 - 09/21/10 07:24 PM
Re: Reg GG
komply
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Gold Star
Joined: Nov 2005
Posts: 265
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What about Money Transimitting Businesses. Is this referring to us selling stored value cards and if so do we need to get verification from our vendor?
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