Someone asked me to explain, in detail, how each type of payment processor could be shut down. I include my post from 2+2 here.
ACH/EFT: Easy to shut off. 80% of all activity goes over a network controled by the US gov. The remaining 20% goes over a small group of networks who are part of the NACHA. NACHA issued the memo that lead to the shutdown of Neteller, Click2Pay, and other payment processors the other week. All they have to do is determine which companies are in the gaming eWallet business. That would be as hard as . . . oh, logging into a poker site and taking a gander at the payment processor page.
Debit/Credit cards: These also travel over a fixed number of networks such. Cirrus and Star are examples. The credit/debit card industry already codes transactions so it’s simple for them to cut off this payment method. Some banks were willing to accept gaming risk but once the regs are published those issuing banks will decline all requests to certain industry codes. If payment processors begin publishing bogus industry codes then Visa and MasterCard would act and completely shut them off as a merchant and/or issuer. This has happened with a lot of other industries say where phone sex lines reported bogus industry codes so Visa and MC already have the facilities in place to address this.
Bank wires are very similar to ACH/EFT. Again, all they need is a list of offenders. I don’t think the DOJ will have too hard of a time supplying a frequently updated list of offenders.
Ewallets are not a payment method, per se. You have to fund them. You fund them via one of the other payment methods (ACH/EFT, debit cards, etc). An eWallet has no value without a way to get money onto and off of it.
Western Union / MoneyGram. WU already doesn’t like people using them to fund online gaming accounts and is more diligent about stopping abuse than is MoneyGram which is why most sites offer some sort of bastardized version of MG under a names like CyberCash. This is more difficult to stop and there will always be ways to slip through but once the regs come out MG will likely be forced to start taking a harder look at all of those cash transfers to the same people in Guatamala, Panama, etc.
Paper Checks are probably the most difficult to stop because they don’t happen via electronic means. The handling of paper checks is actually quite expense compared to other payment methods for this very reason. The biggest problem though will be convienience factor. Paper checks will need to mailed overseas and then cashed by an overseas bank which could take up to a month (for sending as well as funds to clear) though in most cases it would be several weeks.
So realistically the only option that can’t be shut down very easily is paper checks. This is what the banks were lobbying against. They wanted to make sure that they had some wiggle room on paper checks because it would be very expensive (or impossible) for them to come up with a good system to prevent illegal payments to and from online gaming sites.
And that really is the problem. It’s become very public that the US gov thinks online gaming is illegal. That scares away many new players. Now you add in this whole process of having to send checks and waiting for weeks for the checks to clear and that will shut out a large number of new and recreational players.
Plus you have to consider that the government already has a lot of things in place to stop money laundering. Using those same tools against online gaming would make some of the above efforts even more effective.