iGambling

Spineless Congress Hides Internet Gambling Ban in Port Security Bill

2006-10-01T20:36:00.000-07:00

Early in the morning of Saturday, September 30, 2006, a day that will live in infamy, the Senate passed the port security bill after Friday's late night House vote. In a last minute effort the Internet gambling ban, formerly known as H.R. 4411, was added by House and Senate negotiators.

To his credit Senate Minority Leader, Harry M. Reid (D-Nev.) whose home-state casinos are split over the Internet gambling measure, briefly weighed scuttling the bill over the provision before agreeing to go along.

Since the House vote was 409 to 2 and the Senate voted by voice vote, all of these Washington idiots need to hear our collective voice. We say: "ALL IN, throw them all out!!!"

Analysis iGambling Ban Arguments HR 4777 & HR 4411

2006-06-17T09:49:00.000-07:00

Analysis of the Arguments in Support of
H.R. 4777 Internet Gambling Prohibition Act and
H.R. 4411 Internet Gambling Enforcement Act of 2006

Synopsis: Never in U.S. history has such an extensive invasion of the personal and financial privacy of every American been proposed by Congress with so little public debate or apparent awareness. As proposed, every web-site access and every credit card, check and electronic funds transfer will be screened then, if the site or recipient, respectively, is on the government’s iGambling black list and selectively BLOCKED in real time. ISPs, banks and other financial concerns will be deputized by the Justice Department to search continually and instantly for iGambling in every American’s Internet access and financial transaction.

The prohibitionists pushing H.R. 4777 and H.R. 4411, use similar talking points in their support of these two severe intrusions into Americans privacy. Today, the U.S. has “zero” blocked Internet sites and China has 18,931.[1] With the passage of H.R. 4777 the U.S. will add a minimum of 2,500 sites initially, before the tens of thousands of sites with iGambling ad banners with active hot links are added.[2] H.R. 4777 will deputize ISPs to screen continually their roughly 100 million customers’ Internet activity to STOP a few million American iGamblers from doing what they are currently doing.[3] H.R. 4411 will “criminalize the knowing acceptance of credit, credit proceeds, electronic fund transfers or such monetary payments by anyone in the gambling business.”[4] “These proposals do not recognize that the check clearing system and the Automated Clearing House (ACH—[electronic funds transfer]) network do not have the same capacities as the credit card association networks to identify different types of transactions.”[5] “This legislation, if passed, would not only necessitate a massive overhaul of our nation’s check clearing and ACH systems, but also create enormous regulatory burden requiring the deputization of financial institutions to identify and block illegal transactions.”[6]

Money Laundering is Not a Problem. According to a 2006 American Gaming Association White Paper, “Money laundering risks are somewhat diminished with online gambling since all electronic funds transfers can be electronically recorded, providing a detailed and automatic transaction trail not currently available in bricks-and-mortar casinos.”[7] The policies of iGambling sites differ and further frustrate illegal transactions because “withdrawals often have to take place at least 48 hours after the last deposit” and because many sites put daily dollar limits on deposits and withdrawals.[8]

Underage Gambling Is Definitely Not a Problem. There have been no studies cited by the prohibitionists that demonstrate that underage iGambling is even a remote problem. In general, in order to gamble on-line one needs either a credit card or a checking account. All major U.S. credit card companies currently BLOCK the direct credit to any off-shore iGambling site. In any case, Parents should be supervising the use of a minor’s credit card. Minor-owned checking accounts in the U.S. are rare and are all joint accounts with a Parent/Guardian. The set-up time for an on-line iGambling account is seven to ten days using a checking account, involving seven separate secure actions—arguably requiring too much patience for most kids?

Compulsive Gambling Behaviors are Rare. Only about 1% of gamblers are compulsive gamblers.[9] Unlike brick-and-mortar casinos, iGambling sites don’t extend credit to losers. Online gamblers are twice as likely to have a college degree, are younger, are more likely to be single, are more internet-savvy and have less free time than the typical casino player.[10] Elements of this profile are less likely to create “family difficulties.” In any case, an abundance of well-advertised and promoted state lotteries, brick-and-mortar card clubs and casinos, race tracks and extensive legal iGambling carve outs (see below) will continue to aggressively tempt the compulsive gambler.

Governments Often Exempt Favored Forms of iGambling. Existing state and federal laws and the proposed bills have many carve outs for special interests: state internet lotteries, “lawful state-regulated pari-mutuel wagering activities on live horses,” “lawful regulated pari-mutuel wagering on live dogs,” “live Jai-Alai conducted on a closed-loop subscriber-based system” and state-regulated intra-state wireless and iGambling.

Nonsense: “fly-by-night Internet gambling sites.”[11] Partygaming and 888 Holdings have London Stock Exchange market capitalizations of $8.4 billion and $1.2 billion, respectively.[12] Others are looking to go public.

iGambling is Monitored and Regulated. Some 2,500 iGambling sites compete for the gambling dollars. Unlike the few, scattered tribal casinos and licensed card clubs who generally operate (except in Las Vegas and a few other cities) with quite limited competition iGambling sites face strong competition. While iGambling sites may initially compete on the basis of software “look and feel,” table selection and action, bonuses and sponsored tournaments; ultimately, transparency, reputation for fairness, security, web-support, collusion monitoring and quickness of financial transactions are key for repeat gamblers. Unlike brick-and-mortar casinos, the nature of iGambling supports a different type of self-regulation, self-supervision and self-discipline:

User—With software support an iGambler can track every card played, every bet, every hand, every opponent, every table, every session and every iGambling site for any time period. Suspected problems can be reported to the iGambling site.

Bloggers—Web-sites report on every major site with detailed analyses and support forums by iGamblers. Problems become widely known.

Site Supervision—A reputation for fairness, flawless security, and dependability are the key competitive elements in the iGambling market. Sites search for prohibited player software (bots), employ anti-collusion systems, do IP address checks, abide by multiple table tournament policies and use industry standard Thawte SSL (Secure Sockets Layer) Certificates for secure communications. The ongoing security and interface costs force some sites to custom brand the same underlying software network.

Jurisdiction—“Eighty-five jurisdictions around the world regulate some form of online gambling, but most such businesses are clustered in a few places. .”[13] “A March 2005 report listed the following totals for online gambling business, by jurisdiction: Antigua (536); Costa Rica (474); Kahnawake Mohawk (Canada) (401); Curacoa (343); Gibraltar (111); United Kingdom (70) and Belize (60).”[14] Online gambling businesses will be drawn to the United Kingdom in 2007 as it implements its Gaming Act 2005”…Despite higher UK taxes, “U.K. offers substantial advantages: (i) a stable political environment, (ii) vibrant capital markets, (iii) a reliable communications infrastructure, (iv) a large pool of skilled workers, and (v) regulations that should inspire confidence among customers and investors

iGambling is Taxed. Professional gamblers report their income either on Form 1040, line 12, business income (Schedule C) or on line 21, other income. The jurisdictions that license iGambling operations receive tax revenues for their licensing and supervision.

© XtremeSportsStudio.com

[1]Jonathan Zittrain and Benjamin Edelman, “Empirical Analysis of Internet Filtering in China,” Berkman Center for Internet & Society, Harvard Law School, March 2003, 1, http://cyber.law.harvard.edu/filtering/china/ (11 June 2006).
[2] Given the ability of creating multiple access points, this blockage will need to expand exponentially.
[3] “For 2004, estimates of online gambling revenues ranged from $7 billion to $10 billion, with U.S. bettors providing half of that amount.” Revenues are growing 20% a year and millions of Americans gamble on-line. “Deutsche Bank AG/London, Online Gaming Industry, Surreal or Real Returns?” Deutsche bank AG Report, 19 July 2005.
[4] Testimony of Samuel A. Vallandingham, Independent Community Bankers of America, Washington, D.C. at “Legislative Hearing on H.R. 4777, the Internet Gambling Prohibition Act,” United States House of Representative, Committee on the Judiciary, Subcommittee on Crime, Terrorism, and Homeland Security, 5 April 2006, 3, http://judiciary.house.gov/media/pdfs/vallandingham040506.pdf (11 June 2006).
[5]Ibid.
[6]Ibid.
[7]David O. Stewart, Ropes and Gray, LLP, “An Analysis of Internet Gambling and its Policy Implications,” American Gaming Association, May 2006, 16, http://www.americangaming.org/assets/files/studies/wpaper_internet_0531.pdf (12 June 2006).
[8] Mark “the Red” Harlan and Chris Derossi, “Taking Your Cash to Cyberspace—Safely,” Winning at Internet Poker for Dummies, Wiley Publishing, Inc., 2005, 65.
[9] Stewart, 15.
[10] “State of the States: The AGA Survey of Casino Entertainment,” American Gaming Association, May 2006, http://www.americangaming.org/assets/files/2006_Survey_for_Web.pdf (12 June 2006)
[11]Rep. James Gibbons (D-Nevada), July 18, 2000, http://www.techlawjournal.com/crime/20000718.htm
(11 June 2006).
[12] June 2006.
[13] Stewart.
[14] Dresdner Kleiner Research Report on Internet Poker (June 2005).

Score: Red China 18,931 versus U.S. 2,500. Blocked Web Pages

2006-06-02T18:45:00.000-07:00

Under the Internet Gambling Prohibition Act U.S. ISPs will be required to block selected iGambling URLs. Please note that no URLs are currently blocked in the U.S. According to “An Analysis of Internet Gambling and its Policy Implications, “ a American Gambling Association 10th Anniversary White Paper Series, published May 2006, by David O. Stewart of Ropes and Gray, LLP, there are an estimated 2,500 iGambling sites that provide gambling services. Therefore, we give the U.S. a score of 2,500.

Communist China is herein given a score of 18,931, but we are confident that the U.S. will catch up. The path that the U.S. is just undertaking is well documented and researched. Communist China can be our model. The China score was based on an “Empirical Analysis of Internet Filtering in China” by Jonathan Zittrain and Benjamin Edelman of the Berkman Center for Internet & Society of the Harvard Law School. The analysis was last update in March 2003, so perhaps the U.S. will have to enact a few more draconian anti-privacy laws if it has any chance to catch up.

The Zittrain/Edelman analysis can be found at:

http://cyber.law.harvard.edu/filtering/china/

The Stewart White Paper can be found at:

http://www.americangaming.org/publications/10th_anniversary_series.cfm

House Judiciary Committee Approves iGambling Ban Bill

2006-06-02T18:08:00.000-07:00

On Thursday, May 25, 2006, the House Judiciary Committee approved (25-11) the Internet Gambling Prohibition Act sponsored by Representative Bob Goodlatte, a naïve Virginia Republican, and prepared to support a second measure, the Unlawful Internet Gambling Enforcement Act, sponsored by Representative Jim Leach, a naïve Iowa Republican. Goodlatte indicated that a House vote could come as soon as next month, but the bill’s prospects in the more astute Senate are uncertain.

Washington State Law Affects Fantasy Sports Gaming Nationally

2006-06-01T17:57:00.000-07:00

On June 7, 2006, Washington State’s ban on Internet Gaming will take effect. Simply, if a Seattle resident, at home, places a 25 cent bet on PartyPoker on the Internet she is guilty of a class C felony punishable fines up to $10,000 and/or confinement in a state correctional institution for up to five years.

Washington State’s ban, unlike the proposed federal anti-Internet gambling bill, has no carve outs for fantasy sports gaming.

In fantasy sports gaming you buy a roster of players, trade players, rely on the statistical performance of those players through the season and, if you are a superior manager, win a cash prize at the conclusion of the season. Basically, bet--sports outcome—win the pot. That’s gambling. The original target of the Wire Act was specifically aimed at prosecuting sports-based gambling.

That same Seattle resident is a felon if she participates in fantasy sports gaming. Will she be prosecuted—most likely, only if she wins. If she wins, she will not be paid. The fantasy sports gaming sponsors should be reviewing their owners for Washington State residents. While those residents may continue to play the “game” they may (and should) be asked to opt out of any prize pools. Will the fantasy sports organizers be subject to prosecution under this law? Yes. Gambling Commission Director Rick Day has indicated that his commission agents main priority will be national promoters of Internet gaming. Since the foreign iGambling sites are untouchable, the profitable fantasy sports organizers should be easy prey.

The federal carve out for fantasy or simulation sports gaming has three criteria: the win is not dependent on a sole sports contest or player’s performance in a sole sports contest; the outcome is determined predominantly by accumulated statistical results and the prize is established in advance of the game or contest and is not determined by the number or participants or the gross pay-in.

Under Washington Law, RCW 9.46.240 and 67.70.040, if there is any amount of risk such activities would constitute gambling, with the amount of skill of the Internet player being totally irrelevant.

Bottom line: A California (or whatever)-based fantasy sports business can be prosecuted under Washington law. Washington State “team owners” are risking five years in prison to play fantasy baseball this season.

Washington State Voters Irate Over iGambling Ban

2006-05-16T07:31:00.000-07:00

http://www.washingtonvotes.org/2006-SB-6613#comments This link will take you to the legislative web-site that allows voter comments on Washington State's criminalization (a felony) of iGambling. The response is scathing.

Iowa's Rep. Leach Seeks to Ban iPoker: Hypocrite?

2006-05-12T11:00:00.000-07:00

The State of the State was published in May 2006 by the American Gaming Association (AGA). The American Gaming Association (AGA) is the national trade association for the commercial casino industry. This is a survey includes comprehensive economic impact data on the U.S. commercial casino industry. The industry in 2005 generated more than $30 billion in gross gaming revenues for the first time ever.
Two congressional bills aim at curtailing Internet Gambling, including iPoker, HR 4777 and HR 4411. HR 4777 provides criminal penalties including five year imprisonment for accepting Internet bets. Leach provide the substitute bill for HR 4411, which sets up a system to analyze every Internet or payment system transaction AND then to BLOCK any going to an offshore gambling site. This is a horrendous invasion of every American’s privacy.
Leach’s Iowa is a major gambling state with 13 commercial casinos (including three racetrack casinos) and four Tribal Casinos. 8,600 are employed statewide to support $1.1 billion in consumer spending. Iowa’s state gambling tax rate is a graduated tax rate with a maximum tax of up to 22% on gross gaming revenue at riverboats and up to 24% at racetracks with slots and table games. As a comparison, Nevada’s maximum tax is 6.75% of gross gaming revenues. Gross gaming revenue is the amount a gaming operation earns before taxes, salaries and other expenses are paid – the equivalent of “sales,” not “profit.”
Iowa is taking 24% off the top. No wonder Leach’s Iowa gaming supporters fear internet gaming.
iPoker
To obtain a full copy of the 2006 State of the States, contact Holly Thomsen at the AGA at 202-637-6506 or log on to www.americangaming.org.

Ontario, Canada to Ban Ads for Internet Gambling

2006-05-09T09:53:00.000-07:00

Ontario, Canada to Ban Ads for Internet Gambling

Bill 60 2006 is an act to amend the Province’s Consumer Protection Act, 2002 to regulate the promotion of and advertising of Internet gaming in Ontario” “17.1 No person shall print, publish, distribute, broadcast or telecast an advertisement or representation that includes an Internet gaming business website address unless the person believes in good faith that the Internet gaming business has been licensed or otherwise granted permission to operate in Ontario or Canada by the appropriate authority and is operated in accordance with the applicable laws of Ontario and Canada.” This should be interesting to enforce?

Letter from Rep. Goodlatte--HR4777's Sponsor

2006-05-09T09:49:00.000-07:00

Thank you for contacting me regarding Internet gambling. It's good to hear from you. In recent years, illegal gambling on the Internet has exploded into a lucrative business that drains billions of dollars out of the U. S. economy each year and costs tens of thousands of jobs. In addition, illegal gambling serves as a vehicle for money laundering, undermines families, and threatens the ability of states to enact and enforce their own laws. Many of the illegal gambling sites attempt to avoid the application of United States law by locating themselves off-shore and out of our jurisdiction, providing a nearly undetectable harbor for criminal enterprise. These illegal, off-shore gambling websites are unlicensed, untaxed, and unregulated. Gambling is currently illegal in the United States unless regulated by the states. However, the development of the Internet has made gambling easily accessible. The negative consequences of online gambling can be as detrimental to the families and communities of addictive gamblers as if a bricks and mortar casino was built right next door. Online gambling can result in addiction, bankruptcy, divorce, crime, and moral decline just as with traditional forms of gambling, the costs of which must ultimately be borne by society. In addition, the Federal Bureau of Investigation and the Department of Justice have testified that Internet gambling serves as a vehicle for money laundering activities, and can be exploited by terrorists to launder money. In order to bring the current prohibition against interstate gambling up to speed with the development of the Internet, I introduced H.R. 4777, the Internet Gambling Prohibition Act. This legislation cracks down on illegal gambling by updating current laws to cover all forms of interstate gambling and account for new technologies. Under current federal law, it is unclear whether the primary federal law dealing with gambling, the Wire Act, prohibits using the Internet to operate a gambling business. The Internet Gambling Prohibition Act updates and stregthens current law in four main ways. First, it updates the Wire Act to state clearly that the prohibition against interstate gambling includes all forms of gambling such as online poker and slot machines, not just sports-related bets. Additionally, it updates the Wire Act technologically. The Wire Act was written years ago before the Internet existed, so the Internet Gambling Prohibition Act brings the law up to date with new technologies like the Internet and other ways of communicating, such as wireless and satellite capabilities. Third, my legislation makes it a criminal offense for a gambling business to accept electronic funds transfers and other forms of payment. This provision is meant to dry up the money supply that keeps these illegal gambling businesses in operation. Finally, my legislation increases the maximum penalty for violations from two to five years in prison. While this legislation cracks down on illegal gambling across state lines, it protects each State's authority to continue to authorize and regulate gambling within their borders, as long as there are tight controls in place to ensure that gambling does not extend beyond their borders or to minors. I introduced the Internet Gambling Prohibition Act on February 16, 2006, along with 115 bipartisan cosponsors. This legislation was referred to the House Judiciary Committee. No further action has taken place. Rest assured I will keep your views in mind as this legislation moves through Congress. I appreciate you taking the time to contact me. I feel it is important to keep an open line of communication so I can best serve the interests of the 6th District. I hope you will continue to be in touch as the 109th Congress debates issues of importance to the United States. Again, thanks for the benefit of your comments. Please feel free to contact me whenever I may be of assistance. Sincerely,Bob GoodlatteMember of Congress

Constitution's Sixth Amendment v HR 4777

2006-05-04T10:57:00.000-07:00

The Constitution’s Sixth Amendment provides “In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defense.”

The origin of the requirement that trials take place where the crime allegedly took place related to the historical concern that “before the Revolution the British claimed the right to take colonists to England or Canada for trail. This was one of the complaints against the King in the Declaration of Independence.” The Bill of Rights 200 Years 200 Facts.

Except for a few state approved and HR 4777 carve-outs, all of the targeted Internet Gaming sites are located in foreign jurisdictions, where such business are legal and supported by the foreign governments. HR 4777 either has no teeth or is in direct conflict with the Sixth Amendment.

Subcommittee Moves Ban On Internet Poker Forward

2006-05-04T10:42:00.000-07:00

On May 3, 2006, The House Subcommittee on Crime, Terrorism, and Homeland Security, on a voice vote, approved HR 4777 and forwarded it to the full Judiciary Committee. See below, HR 4777 provides criminal penalties including five year imprisonment for accepting Internet bets. Due to congressional elections in the fall, it is uncertain whether this bill and its companion, HR 4411, will be voted on in 2006 http://judiciary.house.gov/committeestructure.aspx?committee=6

http://judiciary.house.gov/CommitteeMembership.aspx

The first link above lists the members of the Subcommittee on Crime, Terrorism, and Homeland Security for the U.S. House of Representatives and the second link lists the membership of the entire Committee on the Judiciary.

Each list provides the hot links to the email mailboxes of the respective Committee members.

Internet Gambling: Prohibition v. Legalization

2006-05-04T08:24:00.000-07:00

The Cato Institute is a non-profit public policy research foundation headquartered in Washington, D.C. The Institute is named for Cato's Letters, a series of libertarian pamphlets that helped lay the philosophical foundation for the American Revolution. In 1998, a generation ago in Internet time, they made a presentation to the National Gambling Impact study Commission. They indicated that law enforcement of a ban on Internet Gambling was futile because: (1) relentless technological innovation ensures that over-burdened agencies will "only fall farther and farther behind;" (2) all Internet gaming sites are outside the jurisdiction of any state and federal agency; (3) Internet's packet switching Cuisinarts each Internet message (funds flow, blind post, call, raise, or fold) into "discrete packets, which travel over various and unpredictable routes until received and reassembled at the message's destination;" (4) the Internet makes it easier to encrypt messages---easy to change addresses---easy to send and receive messages anonymously; (5) the "Internet relies on thousands of separate and wholly private service providers to carry out its deliveries; (6) "the Sixth Amendment of the constitutional Bill of Rights prohibits the criminal prosecution of those who remain overseas while operating Internet gaming sites;" (7) the trend toward Internet gambling has already started--"nine states (this is in 1998 mind you!) already allow their citizens to access professional gaming services at home via telecommunications devices;" and finally (8) consumer demand for Internet gambling and the states' demand for tax revenues will create enormous political pressure for legalization.

Washington State's Ban on Internet Gaming: Class C Felony

2006-05-04T08:10:00.000-07:00

On March 28, 2006, Washington State passed a ban on Internet Gambling. This law raises significant constitutional issues and threatens a Class C felony prosecution on citizens placing 25 cent bets at PartyPoker in their own homes. The law (RCW 9.46.240 and 1991 c 261 s 9) reads:

“Whoever knowingly transmits or receives gambling information by telephone, telegraph, radio, semaphore, the internet (sic) a telecommunications transmission system, or similar means, or knowingly installs or maintains equipment for the transmission or receipt of gambling information shall be guilty of a class C felony subject to RCW 9A.20.021.” A class C felony is punishable by amounts up to $10,000 and/or confinement in a state correctional institution for five years.

Class C felonies in Washington State, include bestiality; assault on a child in the third degree; custodial sexual misconduct in the first degree; third degree rape; four DUIs in seven years; second degree assault; sex and labor trafficking; unlawful taking of endangered fish and wildlife; robbery (1 count); animal fighting abuse or, most egregiously, going “all-in” in a PartyPoker $5+0.50 multiple table tournament. 60 months in jail seems more than appropriate for going “all-in” with less than a pair of jacks.

In order to play with “play money” on PartyPoker, one needs to download and install a program that could be used for either “play money” or cash games. That is a clear violation of the new Washington law. The use of “Whoever knowingly transmits….gambling information.” refers to ISPs, cable companies, DSL providers and phone companies. In order to be “knowingly” a transmitter would have to set up privacy invasive screens that they are extremely reluctant to do---except, maybe to do business in Communist China.

Congress Seeks to Ban Internet Poker

2006-04-23T10:04:00.000-07:00

See blog below for details.

Domestic Spying Via Internet Gaming Bills

2006-04-16T10:18:00.000-07:00

Domestic Spying Via Internet Gaming Bills
Implications for $20 Billion of Immigrant Remittances to Mexico

These two bills aim to curtail Internet Gaming in the US. While HR 4777 provides criminal penalties including five year imprisonment for accepting Internet bets, HR4411 is far more subtly insidious in its privacy invasion possibilities. Leach (R-Iowa) provided the substitute bill to the latter which was approved on March 15, 2006 by the House Financial Services Committee just before the Easter recess.

HR4411 instructs ALL PARTIES involved with the personal payment system, including insured financial institutions, credit card companies, electronic fund transfer (Paypal, for instance), money transmitting services (Western Union, for instance) to follow soon to be prescribed regulations from the Board of Governors of the Federal Reserve System to

"identify and block or otherwise prevent or prohibit restricted transactions through the establishment of policies and procedures reasonably designed to identify and block or otherwise prevent or prohibit the acceptance of restricted transactions" by "allow the payment system and any person involved in the payment system to identify restricted transactions by means of codes in authorization messages or by other means; and block restricted transactions identified as a result of the policies and procedures developed."

BOTTOM LINE: HR4411 sets up a system that will examine EVERY Internet or payment system transaction, screen those that have certain "codes in authorization messages" and then require money transfer service providers to BLOCK the underlying transaction--all in REAL time.

BOTTOM LINE: HR4777 requires ISPs to remove and disable access to an online site violating this section -- "engaged in gaming."

CARVE OUTS: Indian Gaming, state approved gambling and lotteries, interstate horse racing, domestic dog racing, closed-loop subscriber-based live Jai-Alai (whatever that is), and of course, the most risky forms of gambling: securities derivative and commodities trading.

IMPLICATIONS FOR MEXICAN REMITTANCES: Because all Internet gambling is carried on overseas, all payments are consumer-sized, international, and immediately suspect. Mexican immigrants alone remitted $20 Billion in 2005 (Http://www.dallasfed.org/research/swe/soo6/swe0601c.html), every one of these remittances would be initially flagged under this system. Internet gambling remittance sites would set up Mexican-based portals.