The Unlawful Internet Gambling Enforcement Acts Final Rule: Better Late Than Never or Better Left Unsaid?
By Behnam Dayanim and Azba A. Habib
On November 12, 2008, over 16 months after the statutory deadline, the Department of Treasury (the Treasury) and Federal Reserve Board (the Board) (collectively, the Agencies) jointly published the final rule (the Rule) implementing the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA" or the Act). The Act prohibits persons engaged in the business of betting or wagering from knowingly accepting payments in connection with the participation of another person in unlawful internet gambling. The Rule instructs regulated entities on how to identify and block those restricted transactions.