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??

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.

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."

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.

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?

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'?

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!

We have the same space limitations and were able to get it on a statement message.

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?

Anyone?

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?

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!

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.

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.

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.

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.

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.

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.

The portion of Reg GG discussing money tranmitting businesses - is this talking about the bank being an MTB or servicing MTBs?

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.

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.

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.

Existing customers were only required to get the one time reg GG notice and an annual notice is not required. Is this correct?

That is correct.

Thnak you for the confirmation