UIGEA Risk Assessments?

New item we have seen in an FDIC audit is "Risk assessments for UIGEA (Unlawful Internet Gambling Enforcement Act)." It wasn't on our State Exam last year and it wasn't on the FDIC exam in 2012. Not sure what they want, anybody have anything they would like to share in this regard?

Nevermind. Found this post of the same topic.

https://www.bankersonline.com/forum/ubbthreads.php/topics/1773975/Reg_GG_-_UIGEA_Risk_Assessment

The examination procedures instruct examiners to review the UIEGA risk assessment. That means if you have one, they need to look at it. It does not mean you are required to have one.

There simply is no realistic way to assess the "risk" at the bank level. Customer by customer, maybe.