ALL-IN: Internet
BY MICHAEL CARSON AND
THE FINAL RULE to implement the Unlawful
Internet Gambling Enforcement Act (UIGEA) of
2006 is currently in effect, with a required compli-
ance date of December 1, 2009, and it contains spe-
cific requirements for money transmitters, banks,
and card system participants. In this article we will
discuss the major provisions of UIGEA and how
they apply to these payment systems. In addition, we
will examine the response from the Federal Reserve
and the Department of the Treasury to comments
about the definition of unlawful Internet gambling
and a potential “blacklist” of gambling Web sites,
which received considerable atten-
tion from the payments industry.
UIGEA Overview
As the name suggests, UIGEA seeks to curtail
unlawful Internet gambling transactions (
restricted transactions) by requiring payment
systems to establish policies and procedures
to identify and block or otherwise prevent or
prohibit their customers from engaging in
those transactions. The final rule implements
these requirements and identifies the specific
types of payment systems subject to UIGEA,
which include automated clearinghouse systems, card systems, check collection systems,
money transmitters, and wire transfer systems.
