Off Shore Gaming Association

In the United States, big issues sometimes polarize the people and their lawmakers. Slavery was perhaps the biggest debate with no center and caused a civil war. One of the most recent issues where there is no middle ground is abortion. But to see what transpired in the most recent House hearings on Internet gambling and several previous hearings, one would think that lawmakers are deciding another life and death issue. Apparently, when it comes to gambling on the Internet, there is no midpoint, some lawmakers are all in favor and other continue to think this form of gambling is like smoking crack.

Wednesday’s hearing on Barney Frank’s bill, H.R. 2267, the Internet Gambling Regulation, Consumer Protection, and Enforcement Act, started a little late and Chairman Frank rushed through opening statements to get to witnesses. However, there was enough time for Alabama Representative Spencer Bachus (R) to ask “why we would open gambling up to every Blackberry . . . and Ipad.” He added, “How does raking in cash from Internet gambling addicts differ from taking a cut from the heroin sold to drug addicts?”

Now that is some polarizing rhetoric.

Testimony included arguments from both sides of the table. Poker pro Annie Duke, propped up by the Poker Players Alliance, was excellent this time (she had testified in 2008). She must have read my previous BLOG entry because this time around she stressed consumer protection. Players “want to play on sites licensed in the United States, which will provide even greater consumer protections for the player,“ Duke testified. She added “The UIGEA does not keep a single child off an internet gaming site, nor does it provide any protections for problem gamblers or mechanisms to prevent fraud and abuse – it only regulates the banks, not those who operate the games. It is quite candidly a law that appears to be more about burying government’s head in the sand than it is about government providing its citizenry with sensible public policy. H.R. 2267 corrects this untenable posture and puts us in the greatest position to protect consumers and vulnerable populations.” Well said and about time!

Mr. Ed Williams spoke on behalf of the Credit Union National Association and was very eye-opening on what the banks are being forced to do to comply with the UIGEA. “We have handful of transactions that come through and we block all of them because we don’t know which are legal or illegal. He was simply stating that in order to comply that most financial institutions will choose to block all transactions that even appear to be Internet gambling related.

The Honorable Lynn Malerba, Tribal Chairwoman, Mohegan Tribe of Connecticut spoke in favor of H.R. 2267. She mentioned that the Mohegan Tribe had joined forces with other Indian tribes around the country to work with Barney Frank so that “all tribes” can get the benefits of Internet gambling. Unfortunately, she was also the target of Calfornia Rep. Joe Bacca (D). He lambasted her implying that currently the Tribal Nations in the U.S. pay no taxes on the money their casinos generate. She said that is not true and added that the Mohegan Sun pays 25% or its revenue to the state and if possible, she she would prefer the 2% tax in H.R.2267. Bacca claimed that eventually Indian tribes would lose their sovereignty! However, Malerba retorted that she is not fearful of either losing jobs or losing their sovereignty.

Michael K. Fagan, Law Enforcement/Anti-Terrorism Consultant, who was a former prosecutor in St. Louis, railed the entire concept of Internet gambling. He believes that Internet operators will engage in predatory behavior. He wanted to know how the online operator could tell if the player was high or drunk. He took a few softballs from Rep. Bachus and attempted to hit them out of the park citing child behavior that those playing MMOG games would now lose real money instead of virtual points, that identities would be stolen and that most likely it would be the end of civilization as we know it.

One of the big argument that opponents of Internet gambling use time and again in these hearings (Wednesday’s was no different) is that the current prohibition protects our children. I think that Rep. Frank said it best when he said that ‘ the poor children here are being used by people who don’t like gambling.”

Perhaps the best part of the hearing was when Rep. Bachus pulled out a giant picture, so big he had trouble holding it up, showing the headquarters for the Safe and Secure Internet Gambling Initiative. It was a picture of a UPS store in Washington, D.C. Rep Frank hit the gavel, making him put it away quickly. Hilarious.

But there is nothing funny about this debate. The sides are so diametrically opposed that there appears to be no middle ground; no compromise in sight. The bill is scheduled for markup (changes) on July 27. Unfortunately, it does not appear that Rep. Frank and others will ever be able to include enough alterations to H.R. 2267 to ever get the other side to see the light.

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In 2006 the United States Congress decided to make the U.S. Financial system the enforcement for Internet gambling with the passage of the Unlawful Internet Gambling Enforcement Act (UIGEA). But, the new law would not be put into effect until the rules that the banks would be forced to follow were finalized. They were finally supposed to be implemented by December of last year, but Rep. Barney Frank and the House Finance Committee were able to block the implementation, at least for another 6 months. Well, six months is up and June 1 is the new date for banks and payment processors to block all transactions associated with ‘illegal online gambling’.

One of the biggest sticking points for Frank and the banks was what constitutes a payment to an ‘illegal’ online gambling operator. After all, no one in this administration or any previous ones has been able to actually define what that ‘illegal online gambling’ is, and thus banks and payment processors really do not know which transactions to block. The fear amongst Frank and his legislative buddies was not only the cost to financial institutions (always a biggie when you have the ear of the banking lobbyists), but the fear that any suspected transactions, including legitimate ones, would be denied.

The OSGA has been getting swamped with inquiries as to what would happen come June 1. We have been telling players since the passage of the UIGEA, that the movement of money for the purposes of gambling online, except for U.S.-based horse racing sites and lotteries, is illegal because of the 2006 law. We also have spoken with online gaming companies worldwide who tell repetitive horror stories, usually involving getting money back to players in the States. In reality, the banks are already doing more due diligence on ‘suspected’ transactions. We have reported on many companies that process money back to U.S. players which have been shut down and had funds confiscated for several years. As it turns out, the effects of this law have already been felt, and it’s not yet June.

Last week we got a disturbing report that a player had his debit card shut down by his local bank. Apparently, he had made several deposits with an online gaming operation located off of U.S. soil. These transactions were identified as illegal and his debit card was shut down, I guess so that he could make no further deposits with it. This is quite alarming, as it was not the transactions that were blocked, it was the players debit card that was shut down. His account remained open, but his card was shut down.

This may be an example of the frustration that the banks are going to have with ambiguous rules and regulations. Unfortunately for everyone, the UIGEA makes financial institutions police, judge and executioner. They will simply block first and ask questions later. In New Hampshire and North Dakota, overblocking led to denial of legal online lottery purchases several years ago. The blocking of legitimate transaction is one of the biggest arguments against the ambiguous UIGEA. Yet, who can blame the banking system? They will be fined if they process money to/from an Internet gambling house, even if they just missed a check or debit.

It is important to keep in mind that the UIGEA was not written to go after any player sending money offshore or receiving payouts from gaming companies. Instead, it enforces steep penalties on financial institutions for allowing ‘illegal Internet gambling’ transactions to occur.

The same player continued to have bad luck at his bank. The same week as the debit card incident, he went to the bank to deposit a check he had received for a payout from the same book. The bank claimed that the check was bad, and was looking for additional information. Instead the customer checked with the book, found out that the check was indeed good and simply asked the bank to redeposit it. Of course, the check cleared. And of course . . . once it did . . . the player opened an account at another bank.

This player’s story and his particular bank may be an isolated incident, or this case may be the tip of the iceberg. No one can be 100% sure. But this one occurrence should show players at Internet sportsbooks, casinos and poker rooms, that these regulations are making a real impact, implemented or not. Though we believe that the online gaming companies that service U.S. players are always one step ahead of the long arm of U.S. law, you can never be too safe with your money. Players should take care with how they are sending and receiving money and now, more than ever, keep an eye on balances.

If you have had a problem with your bank and the UIGEA regulations, please add your comments below.

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On Wednesday the U.S. House Ways and Means Committee held a hearing on Senator Jim McDermott’s (D., Wash.), latest revision of an online gambling tax bill introduced in 2009, H.R.2268. For over a year this bill has sat around while Internet gambling grows and state and federal coffers dwindle. The hearing engaged much of the same rhetoric that we have heard since the passage of the UIGEA in 2006, but this discussion was more spirited than many Federal hearings, perhaps, because this one was focused on the money.

And Big Money is what was being discussed. How ‘bout $42 billion over ten years! That is the figure that was thrown out early by Rep. Barney Frank (D-MA), who had to leave almost immediately after his testimony to take care of slightly more important national issues, like legislation designed to boost bank lending to small businesses. 40-plus billion is a huge number and is predicated on McDermott’s complex tax scheme involving operators paying a 2 percent tax on customer deposits, a one-quarter percent tax on wagers and the tax generated from gamblers who would now pay on their winnings in the form of a 1099 at the end of the year from their favorite online casino.

A good deal time was spent exploring the deposit tax. Several senators could not fathom that there would be a tax when making a deposit. They likened this as to a tax when a consumer ‘walks into Sears to buy a refrigerator with $1000 in their pocket’ and is taxed, whether a purchase is made or not. This line of archaic thinking came from multiple sources at the hearing. Finally towards the end of the hearing McDermott brought some sense to the argument noting that gamblers are not the ‘type of people’ to leave their money in the account. “That money to be deposited will be gambled”, said McDermott.

Even though this was supposed to be a hearing on the tax bill, it quickly turned into the usual point-counterpoint on the rewards/evils of online gambling. Opinions were all over the place with some legislators hitting on points that seemed to have nothing to do with the taxation of Internet gambling. Job creation, problem gambling, and the who, what and when of regulation were discussed. Advocates made legitimate arguments while opponents brought up much of the tired commentary that led to the current prohibitions.

Once again Rep. Bob Goodlatte (R-VA), architect of the 2006 Unlawful Internet Gaming Enforcement Act (UIGEA), brought up the suicide of a constituent. Though these stories are sad, the constant reminder of them brings to mind Tipper Gore saying that heavy metal music and Ozzy Osbourne prompted kids to kill themselves and others in the 80s. Rep. Wally Herger (R-Calif.) wanted to know at the outset why there was “even a hearing being held” when 317 legislators voted for the UIGEA. He did not reveal that the UIGEA was attached in the 11th hour to a homeland security bill that was pretty much a slam-dunk for passage.

Clearly Herger is obviously an opponent, as is Goodlatte, who spent a good deal of time being grilled by regulation advocates including, Rep. Charles B. Rangel (D-NY) and Rep. Earl Blumenauer (D-OR). However, Goodlatte takes a unique approach when being questioned. When asked, he punts and allows State’s rights to play defense for him. The questioning of Goodlatte went something like this. Q: Bingo. Goodlatte: States rights. Q: Poker. G: State rights. I think if it were up to Bob Goodlatte, we would have no Federal Laws, the states should be able to regulate every aspect of life.

There are clearly lines being drawn between supporters of Internet gambling and those that think the current prohibition is the best way for the country to go. Rep. Blumenauer commented that after the UIGEA legislation “people are still playing” and Rep. Linda T. Sanchez (D-CA) said that we are doing nothing more than “taxing what is already going on offshore”. Rep. Shelley Berkely (D-NV) added in that she supports legislation and regulation, but cannot give the OK to this tax bill. I guess Las Vegas thinks they pay enough taxes already. There was talk of limiting funding to political campaigns via gambling proceeds and whether the IRS will need more people and what about the Tribal Nations and their gambling? Clearly this is going to take some time . . .

Here are a couple of my favorite quotes from the two and half hour hearing.

Danny Davis, (D-IL) (neutral): “I think freedom of choice is a real concept.”
Sanchez, (D-CA) (for): “Today we are talking about a revenue stream.”
Earl Pomeroy, (D-ND) (against): “We can’t gamble our way back to a balanced budget.”

These three quotes are a microcosm of the realization that Federal legislation for Internet gambling is still a long way away from any type of resolution. The two sides are so far apart they cannot even get together on the most important aspect of legalization and regulation, at least as far as the government is concerned – how to collect the money. As long as legislators like Bob Goodlatte keep bringing up letters from States Attorney Generals and the sports leagues and the FBI and is allowed to put them into the record (again and again) then the road is long and uphill for legalization in the U.S. In the meantime, U.S. gamblers keep playing, offshore companies continue to benefit and the American consumer is the one who loses.

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The latest round of hearings initiated by Barney Frank regarding his continued effort to repeal the UIGEA and legalize and regulate internet gambling were certainly not at the top of any legislators ‘to do’ lists yesterday. The lightly attended and I mean lightly attended, hearing basically pitted Frank against gambling’s latest arch enemy, Representative Spencer Bachus from Alabama. The hearing lasted about 90 minutes and towards the end Frank noted several times that they had to finish so that they could vote. I guess he looked around the empty seats and realized that there were not enough present. Frank ended the hearing by letting us all know that this debate will continue into next year. And probably the year after that and the year after that……

Frank started the proceeding and spun his usual stance on personal freedoms. “The notion that this Congress should tell millions of adult Americans that we know better than they, what they should do with their own money, on their own time, on their own computers seems to me to be a very grave error and I hope that this whole legislation is repealed.”

Bachus, on the other hand, not only hammered his usual rhetoric about children becoming gambling addicts. He fabricated the statement, “in the next 5 years we will create a generation of 10s of millions who from their youth will be addicted to Internet gambling and therefore lifelong problem gamblers”. Bachus also stated emphatically that he would “do everything I can to make sure this never happens.” He also added that online gambling is “particularly predatory and an abusive intrusion into American homes.” Wow, I guess that anyone could simply turn off the computer to stop the intrusion.

Luckily, in Frank’s rebuttal, he stated that there was no basis for the millions of addicts that Bachus claimed and added that, “I don’t think this is simply about protecting young people . . . there are some people who do not want gambling.” He added that the notion that you end the legal ability for Americans do to anything because some people will abuse it is a ‘recipe for the destruction of individual freedom.”

So, after the only two representatives who seem to really care about the issue were done (or present), the testimony started. In the interests of space and so as not to rehash the entire hearing, I will break the testimony down into three groups, those for or against the legislation and those who were simply testifying to provide information. If you would like to view the hearing in its entirety, click here.

FOR the repeal of the UIGEA AND legalization:
Mr. Samuel A. Vallandingham testifying on behalf of community bankers noted that the financial payment systems were not designed for trapping and prohibiting unlawful internet gambling transactions. Obviously, the banking community does not want this burden so it was no surprise that he and his group support H.R.2266, to repeal the UIGEA. But, apparently the small bankers of America also support H.R. 2267 because once clear legalization and regulation occur, then the banks won’t have to figure out what illegal gambling is.

Mr. Mike Brodsky, representing YouBet, the online race book based here in the U.S. came out in favor of both bills as well with a convincing argument. He referred to the current stat of Internet gambling as a ‘Wild West affair” that is “out-of-control’. But, he came out with one off the best statements of the morning. “Enacting H.R.2267 is the most effective way of achieving the stated goals of some of the bills harshest critics.” During the Q & A period after the testimony was completed he helped Mr. Frank make a point that the different branches of government see Internet gambling differently, specifically that the DOJ calls all Internet gambling illegal. Brodsky answered this question by stating that 88% of all pari-mutuel wagers placed in the U.S. are placed across state lines!

Ms. Parry Aftab runs WiredSafety, a volunteer non-profit internet protection organization. She was the most compelling speaker of the day and said that Internet gambling is a consumer protection problem. She stated that though she does not “advocate gambling anywhere . . . We need to do something because what we have right now is not enough”. “The only way to protect consumers from online gambling risks is by legalizing it. If we don’t legalize it - we can’t regulate it.”

Those who were non-committal and/or were just providing information:
Professor Malcolm K. Sparrow who ran a study, funded by the Poker Players Allliance and Harrahs, for the Wired Safety group, focused on managing risks. He noted three ‘unregulated’ jurisdictions – Antigua, which does actually regulate their operators, the Kahnawake Indians in Montreal and, of all places, Grenada, which currently has no Internet gambling operators. Though Sparrow does not show the greatest grasp on the industry, he did provide some solid insights. He stated that in the current U.S. scheme the America incurs all of the social costs while exercising no jurisdiction and offering consumers no protections. He said that he would expect that in a regulated environment most consumers would move from offshore operations to licensed ones.

Mr. Keith S. Whyte, the executive director of the National Council on Problem Gambling stated that internet gambling in the U.S., Canada AND the UK is the LOWEST form of problem gambling. He also said that his group did not see any decrease in help line calls after UIGEA was enacted.

Mr. Jim Dowling, a former special agent with the IRS who now works with casinos and financial institutions came the closest to putting everyone to sleep. The only worthwhile thing that he added was that any blacklist of offshore operators would be out-of-date as soon as it was published. He wanted to keep dulling us to death but Frank cut him off before anyone started snoring

The only full opponent of these two bills was The Honorable Robert Martin, Tribal Chairman of the Morongo Band of Mission Indians in California. He wondered why Congress would want to protect foreign illegal operators - legalize offshore gaming at the expense of local jobs. He felt that Internet gambling would put the Tribe at a competitive disadvantage to Internet operators. I guess he also thought that selling Manhattan for a bunch of beads was good business, as it would be obvious to the casual observer that an Internet presence will only enhance any land-based gambling operation. Martin was reading from a prepared statement and appeared like he was looking for his foamy red nose and big floppy shoes whenever he was asked a question by the legislators.

The final phase of these hearings is always a question and answer session with the panel of witness. This is always an entertaining segment, especially with Bachus asking the questions. And, he did not stop mystifying. He spent the bulk of his ammo trying to discredit the proponents of the bill with questions like this one to the executive director of the National Council on Problem Gambling. “Harrah’s is one of your main contributors, right.” A befuddled Whyte replied looking more like this :>O. He stated that Harrah’s is one of the councils sponsors and contribute $5000 annually.

However, a new player did emerge during this phases of the hearing. Peter T. King, the ranking member of the Committee on Homeland Security made a statement during the Q & A. His powerful words included, “All prohibitions are well intended - sometimes they work, sometimes they don’t. Usually they don’t. In this case I don’t believe it is - we are losing revenue and we’re not achieving the social purpose that was intended. I strongly support this legislation.”

And so do we. This hearing was the first one out of all of them I have endured where I came away feeling positive. The scale is tipping and may be getting heavy in favor of legalization. But unfortunately, we will all have to wait until 2010 for the next round and the potential for any real change here in the U.S.

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Barney Frank has managed to find time amongst the financial meltdown, health care and the global war on terror to arrange for a full hearing of the House Financial Services Comittee on his two ‘gambling bills’ - H.R. 2266, Reasonable Prudence in Regulation Act, and H.R. 2267, the Internet Gambling Regulation, Consumer Protection, and Enforcement Act. This hearing most likely will not produce any great changes, but it is a good sign. A sign that perhaps Washington is realizing that they can’t stop Internet gambling, so, maybe a legal, regulatory stance would be better than the prohibitionist tact that has prevailed via our legislators in recent years.

“The government should not interfere with people’s liberty unless there is a good reason,” Frank said. “This is, I believe, the single biggest example of an intrusion into the principle that people should be free to do things on the Internet. It’s clearly the case that gambling is an activity that can be done offline but not online.”

H.R. 2266 is almost a moot point by now. On Black Friday the government delayed the implementation of the UIGEA for 6 months. Mr. Frank’s bill is looking to delay it for a year. 6 months, a year, either works in the favor of everyone involved. However, by delaying the implementation of the regulations for basically all of 2010 it would give Frank’s other bill a chance to gain some ground. H.R. 2266 has a total of 54 sponsors who hopefully will attend the hearings.

Hr. 2267 is the big one. And it has more support with 63 co-sponsors. This is the bill to actually legalize betting on the Internet here in the U.S. Well, at least for poker and potentially casino games and other forms of gambling, but not sports betting. That is hurdle that no one is willing to tackle . . . yet.

The bill states that “Internet gambling in the United States should be controlled by a strict Federal licensing and regulatory framework to protect underage and otherwise vulnerable individuals, to ensure the games are fair, to address the concerns of law enforcement, and to enforce any limitations on the activity established by the States and Indian tribes.” Opponents argue that legalized online gambling is a danger to our youth and this bill includes safeguards to prevent underage or compulsive gambling and other illegal activity, to protect consumers who gamble online. To further emphasize this point, the name of the bill, unlike former versions by Frank and Robert Wexler, now includes ‘Consumer Protection’ in its name.

The most significant thing that these hearings give the Internet gambling community, operators and U.S. players alike, is hope. Hope that someday, in our lifetime, placing a wager from the confines of you own home will be 100% legal and regulated in the States. The last time Barney Frank brought a similar anti-UIGEA bill before the Finance subcommittee there was a tie vote to move it out of committee. And in the U.S. Government, a push is a loss. A single vote in favor of what was then H.R.5767 would have accelerated this process and hope would have been alive for the past 13 months. We urge all readers to contact their Representatives. You can find your reps here. Please take action today!

Taking action is the most important thing that a concerned online player can do to support online gambling in the US. The OSGA can’t do this alone. A successful hearing on Thursday will hopefully lead to a Committee vote in support of these bills.

You can view the proceedings live starting at 10AM on December 3 via the house.gov website. View the debate directly here.

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As banks in the US prepare for the implementation of the Unlawful Internet Gambling Enforcement Act (UIGEA) in December, customers of internet sportsbooks, casinos and poker rooms are growing nervous.

Make that more nervous. We have gotten dozens of calls and emails all wondering what this means for Internet gambling, several have viewed this as ‘the end’. However, this appears to be just another scare tactic from the U.S. government. This law, though it has a catchy title and a cool acronym that appear to give the it teeth, really appears that it will have little or no effect on the current state of money movement to and from Internet gambling houses.

The American Bankers Association, a trade group that “works to enhance the competitiveness of the nation’s banking industry” and represents over 95% of the country’s banks, clearly notes that the Final Rule on the UIGEA issued December 18, 2008 is aimed at companies and credit cards. Banks are now required to do more due diligence at the time of account opening to deny commercial entities that may be acting as Internet casinos access to the payments system. It also requires that policies and procedures be implemented to prevent all debit and credit card payments to Internet casinos. However, it does not require that checks, ACH payments, or wire transactions related to Internet gambling be monitored or blocked.

So this UIGEA is clearly aimed at financial institutions and gaming companies, not players. There is no mention specifically of the tried-and-true funding methods of Western Union or MoneyGram. Nor does it appears that recent inroads by some gaming companies into using ACH (where the player’s bank account is directly debited) as a form of funding will be stopped, or even looked at. As with most of the beliefs on Internet gambling in Washington, lawmakers once again are misguided here. They must think that the main source of funding a gambling account is via credit card. Or that 123sportsbook opens a bank account in the U.S. under the name 123sportsbook!

We recently polled a dozen very reputable gaming companies offshore. We were trying to find out what preparations they were making as the December 1 doomsday approaches. The most common response included the sentiments, “You know far more than we do about this one.” Bookmakers offshore have had to skirt the ever-evolving U.S. laws since they took their first bets from foreign soil, so most view this as just another ‘bump in the road’. Clearly the December 1st date is nothing like the final game of a winning ten-team parlay to offshore bookies. And, should the bump in the road become a roadblock, the offshore outfits will get creative. They always have and seem to have an uncanny knack of staying one (or more) step ahead of regulators and legislators.

Still, players have grown increasing anxious. The government propaganda machine is clearly in override as the date approaches. To that end, recent bank statements and emails sent to customers’ state, in one form or another, that restricted transactions related to unlawful Internet gambling are prohibited from being processed.

Check out what TD Bank put on this month’s statement to customers.

These declarations are required by the 2006 UIGEA. The strange thing is that they are showing upon personal bank accounts when the law clearly is aimed at the businesses involved in Internet gambling, not the players. We asked a local bank manager who said the credit/debit card portion of the UIGEA final rules forced banks to put out the misinformation to its customers. Banks must have policies and procedures that would prevent credit and debit card transactions from being made to Internet casinos for unlawful Internet gambling by any of its customers, including individuals. But, banks may rely on the existing policies and procedures established by the card networks and they do not have to create a separate process.

Thus, it may become even more difficult to use credit cards to fund your offshore gambling endeavors. However, as many players can attest, the use of credit cards at many Internet sites is not easy or reliable. Cards get rejected regularly, and the additional paperwork generated and rules enforced at offshore books and casinos make the use of Visa and MasterCard sketchy at best.

The bottom line for players is that if you use a credit or debit card and it has had issues in the past, forget it after December 1. We would also suggest not using a credit or debit card from any new bank accounts or avoiding cards all together if looking to ensure that your gambling remains under the radar.

Again, your bank is not required to block ACH, wire, or check payments related to unlawful Internet gambling to be in compliance with the Final Rule. So, if you choose to gamble online, knowing the pitfalls and the fact that the government does not want you playing, there is no need to worry about getting a check payout. If you want to ACH a deposit to your favorite book or poker room, go ahead. Looking to receive a bank wire? No problem.

As far as the operators? It is and will be business as usual. Money movement has been an issue for sometime offshore. Most Internet operators use systems that are not directly related to gaming. They are constantly looking for new funding and payout methods, knowing that if they can’t pay customers, they are out-of-business.

If you are an Internet gambler, there really is no reason to run from your offshore account. Or from your government. They are just trying to scare you. The UIGEA is just another law that has little success in living up to its name and actually enforces ‘illegal internet gambling’, whatever that is.

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