
The regulations drawn up to enforce the US ban came under particular fire last December in a letter submitted to the United States Department of the Treasury by the American Banking Association.
The eleven-page document submitted by the ABA focuses on a number of specific aspects of the guidelines under the UIGEA. In essence, the responsibility to police illicit financial transactions between US gamblers and gaming firms (poker rooms, casinos, bingo sites etc.) based offshore falls on the banks' laps.
The general thrust behind the ABA document calls into question the overall viability of the government's strategy of placing the onus on the banking system to enforce the gambling prohibition.
The document declares the following: "The ABA believes that the proposal, in large part due to the nature of the statute itself, will fail to create a practical process for intercepting prohibited conduct that maintains an efficiently functioning payments system." The appeal continues with, "the UIGEA will in the end catch more banks in a compliance trap and do greater damage to the competitiveness of the American payments system, than it will stop gambling enterprises from profiting on illegal wagering."