http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1688122#Post1688122

I have a question posed in the thread above and not sure where to post it exactly.

If someone is using real money to play gambling games on Facebook, and the website for payments is held overseas ... should we be blocking these transactions?

These types of consumer transactions are not covered under Regulation GG, so any decision you make will be a bank policy decision.

I agree with you Randy, and I've argued that point until I was blue.

However, examiners have been pointing to random sections of Reg GG. Like:

"(a) Actual knowledge with respect to a transaction or commercial customer means when a particular fact with respect to that transaction or commercial customer is known by or brought to the attention of:
(1) An individual in the organization responsible for the organization's compliance function with respect to that transaction or commercial customer; or
(2) An officer of the organization."

"(bb) 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"

"All non-exempt participants in designated payment systems shall establish and implement written policies and procedures reasonably designed to identify and block or otherwise prevent or prohibit restricted transactions"


They (examiners) are stating that if we can block, we should be. & they use Reg GG as their citation.

I know Reg GG is for businesses that engage in unlawful internet gambling (how FB gets away with it is beyond me).


Questions to help me: Can I cite something else to the customer to justify why we are blocking the transactions and do you agree that these types of transactions could be unlawful internet gambling? (outside of Reg GG?)


Thank you!

Point to your deposit contract and tell them either to knock it off or you will close their account, or depending on the current relationship exercise your right to close the account for any reason and close it now. You don't need to cite any regulation.

These ACH transactions are exempt under 233.4(a) if you want to enlighten the regulators.

Thank you Randy!

Sorry, one more question ... Are Debit Card transactions exempt as well? (because that's what these are)