My Take On The UGIEA Regs

You can read the just released regs here. Perfect reading if you are having trouble sleeping.

First, let me say that these regs are VAGUE AT BEST. Simply put, the regs are designed to filter out the "suspect" transactions at the "border crossing" stage. This means the transactions are reviewed when they become international transactions. I'm guessing this design was meant to keep the onus off the local banks, so they won't piss off the end user (you & me). "Sorry Mr. Buffalo, your transaction was denied by the intermediary bank. Enjoy your free toaster."

These regs are so convoluted - trying to appease everyone involved (in enforcement) - that they are almost just ideas and not actual rules. There are no real specifics, as I can see. So I wouldn't be surprised if you don't see any real analysis soon from the heavyweights (Russ Fox, I. Nelson Rose, etc.).

Here's what I do know:

Playing poker is not illegal. It has never been illegal. These rules do not try to stop poker playing. The Justice department has publicly stated they have no intention of prosecuting poker players under any circumstances.

These proposed regs do not (and should not) affect cashing out of poker sites. I know people argue the "If no fish are depositing the games suck" routine, but as long as I continue to get my advertising and rakeback, I want (and need) a secure cash out mechanism.

Finally, all of this begs the question:

How will the regs affect ePassporte? The REAL test will come when Youteller (or some new e-wallet outside the US) begins processing these transactions. Then we will finally know if these regs have any teeth at all.