I read this regulation when it came it out a while back and somehow came to the conclusion this was not effective until December 1, 2009. Now, someone said it is effective 1/19/09.

We are a small community bank. We do wires, have ACH, etc. Doesn't that put us in the 12/1/09 category?

Help!

It's effective 1/19/09; however the mandatory compliance date isn't until 12/1/09.

The way I read this, we only have to worry about having customers who engage in the business of internet gamling, as opposed to Susie Stinker who actually gambles on-line.

Did anyone else read it that way or am I just lost in dreamland?

My first time reading it through that is what I thought too, but now I am not so sure. Why would we have to set up systems to monitor wires, etc. if we don't have to monitor everyone for illegal gambling?

There was a webinar -but I was told "no training" this year (no money) so I need to figure it out myself or with the help of BOL users (Thank God for BOL!). I also have to somehow figure out a way to pay for all my required CE CRCM credits myself! That should be fun! (sorry for the semi-vent there!)

During an ABA teleconference yesterday they stated that no monitoring of customer transactions is required. It appears the rule appplies mainly to commercial customers that may be operating as an internet casino.

It does say that policies and procedures must be created to prevent prohibited debit and credit card transactions. Financial institutions can rely on the written policies of the network they use.

Also stated was that the networks usually have merchant codes assigned entities and this could be a way to block all gambling transactions.

Hey- thanks! That is very helpful information!

In the ABA conference call, they also mentioned that a letter should be sent advising the customer(s) that these types of transactions should and would be blocked. But no sample verbiage for said letter......yet.....

I too am confused as to whether we have to monitor our consumers to make sure they are not gambling illegally, or if we just have to monitor any businesses that are in the business of gambling and potential illegal gambling? Can someone please clarify?