Topic: Regulation GG
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On the advice of our internal auditor, we recently updated our BSA policy to provide our response to a discovery of an ACH transaction that is connected to unlawful internet gambling. How can we detect these ACH transactions? Does NACHA provide any guidance?
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We are not aware of any specific guidance from NACHA on identifying ACH transactions involving illegal gambling. Regulation GG itself includes examples of policies and procedures to identify illegal gambling transactions, which include due diligence on commercial customers to determine the risk that the customer will engage in internet gambling and notification that your bank…
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Are you aware of any law or rule that would prevent us from blocking all online gambling transactions, even if lawful? Also, does the state of Illinois need to take action on the new merchant category codes for lawful gambling transactions before merchants can begin using them? How are gambling businesses assigned codes?
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No, we are not aware of any law or rule that would prohibit you from blocking lawful gambling transactions, assuming that your account agreements permit you to block those transactions. When Regulation GG was issued, the Federal Reserve stated that it does not require financial institutions to process gambling transactions if they have decided “for…