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Unlawful Gambling
Enforcement Act of 2006
Executive Summary
Table of Contents
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to Federal Actions
Unlawful
Internet Gambling Enforcement Act of 2006
Title VIII was added in the wee hours of Saturday, October
2, 2006, as the final congressional act just moments prior to the pre-election
break and would arguably never have passed the Senate in the 109th Congress. e
Republican leadership conspiratorially and callously poured their Internet banning Draino
® down the gullets of Congress and the American people under the cloak of
darkness. This caustic liquid now eats away the innards of personal liberty and
Internet rights.
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Criminalization
The Act does not criminalize the player-gambler, but
targets the operators of net casinos. However, those operators are all
unlikely to face prosecution in the US, except those subject to extradition
treaties or those too dumb to avoid traveling to or through the U.S.
The Act exempts, in general: risk less gaming, intrastate
State or tribal wagering with effective geolocation and age verification
systems, activities related to horse racing under the Interstate Horseracing
Act, interstate transmission of information relating to State-specific lottery
between a State or foreign country and fantasy or simulation sports gaming.
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Enforcement Provisions
Catch the Bootlegger: The arrest,
extradition, conviction and incarceration of foreign operators of net casinos
are the only foreseeable punishments in the Act. ISPs and financial companies
are deputized to enforce many of the Act’s key provisions.
Close the Speakeasies: Under the Act, the U.S. will go from “zero” blocked Internet sites to
approximately 2000 sites initially, before tens of thousands of “hypertext link(s) to online site(s)” are required to be removed or disabled. The Act
deputizes “Interactive Computer Services,” which include: ISPs, search engines,
libraries and education institutions. These cyber-deputies are required to
SCREEN the surfing activities in real time of approximately 100 million US users
in order to STOP at most eight million sporadic, recreational web-gamblers.
Interactive Computer Services will each choose and contract with commercial
Internet security systems companies to provide filter technologies. These
companies currently offer a menu of block able content categories from gambling
to politics to their customers: ISPs, businesses, government agencies,
educational institutions, libraries and not-for-profits. The Act suggests that
the Justice Department will provide “notice” of additional censored sites on an
ongoing basis.
Follow the Money: The following quotes are
from Samuel Vallandingham, on behalf of the Independent Community Bankers of
America, during the “Legislative Hearing on H.R. 4777 [merged with H.R. 4411],
before the Committee on the Judiciary, Subcommittee on Crime, Terrorism, and
Homeland Security on 5 April 2006. The Act will “criminalize the knowing
acceptance of credit, credit proceeds, electronic fund transfers or such
monetary payments by anyone in the gambling business.” The Act barely
recognizes “that the check clearing system and the Automated Clearing House
(ACH) [electronic funds transfer] network does not have the same capabilities as
the credit card association networks to identify different types of
transactions.” The ACT, 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 tens of thousands of
financial institutions to identity and block illegal transactions.” While the
Bank Secrecy Act of 1970 requires reports for amounts from $10,000 for bank,
casino and business currency transactions—smaller (to $2,000) for suspicious
transactions, this Act, requires financial institutions to block or to refuse
honoring restricted transactions as small as $1.00. The Act does give the
Secretary of the Treasury and the Federal Reserve Board a 270-day period from
the Act’s date of enactment to devise an enforcement plan or “find that it is
not reasonably practical to identify and block, or otherwise prevent or prohibit
the acceptance of, such transactions.”
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Table of Contents.
The Mosaic of Authoritarianism
All Internet Activity Filtered: The Act will
significantly alter the implicit privacy of all Americans by setting up an
entirely new system to scrutinize through filters all Internet visits. While
only foreign gambling sites and U.S. hot links to them are expected to be
blocked, the system is capable with a key stroke of expanding into other content
categories. Well-intended, future laws could easily further narrow the range of
Internet content to US citizens.
All Financial Transactions Codified:
The Act requires the codification of all banking transactions for the sake of stopping less than
1/1000 of 1% of on-line gambling exchanges raises serious issues of governmental
intent.
All Email, IM, Chat Room and Web Surfing Cached for
Two Years: A separate initiative with respect to child endangerment
will add a tile to the mosaic of authoritarianism. While unrelated to the Act,
the likelihood of enactment in the 110th Congress is enhanced following the
ex-Congressman Mark Foley congressional page fiasco. Because of the general failure of local law
enforcement agencies to promptly follow up on child endangerment leads from the
National Center for Missing & Exploited Children (the “NCMEC”), the Justice
Department is pressuring and Congress is threatening legislation to cause ISPs
to cache senders and receivers of emails, chat room and IM participants and
extensive Internet histories for all 100 million US users for a evergreen
two-year period. While identifying and prosecuting exploiters of children is a
noble initiative, NetRightsAdvocates strongly believes that this initiative
raises severe privacy issues and is misguided and dangerous. A better approach
is to make additional resources available to local law enforcement agencies to
follow-up promptly to the NCMEC’s specific leads so that court orders can be
requested and issued and each pervert’s Internet records obtained on a timely basis.
Caching 120 billion unique page views for 100 million Americans to provide
possible prosecutorial evidence on a thousand perverts is misguided and
dangerous.
All International Transactions Monitored:
Concerns have been raised about the Executive’s Branch’s monitoring over the
Swift (Society for Worldwide Interbank Financial Telecommunication)
international financial system.
All Americans International Calls and Emails Subject
to Monitoring: Additional concerns continue over Bush’s 2001 directive
which authorized the National Security Agency to monitor, without court
warrants, American’s international calls and emails when terrorism is suspected.
The Mosaic of Authoritarianism: Each tile
above is supported by arguably valid public policy concerns, but the mosaic of
authoritarianism is clearly pictured when all the tiles are assembled.
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Conclusions and Recommendations
We believe that Internet
gambling should be legalized, regulated and taxed. Such an approach would
ensure age and identity verification, the integrity and fairness of the games
and that responsible gaming features are prominently featured. Congress
fails to appreciate the creative ability of Internet users to avoid their
collective nonsense.
A short-sighted Congress has cost tens of thousands of American jobs in an
industry, Internet gaming, which the US could have easily dominated with it
well-established, well-respected international gaming concerns and gambling
commissions. US software programmers and computer, router, server manufacturers
should have designed the next generation of Internet gambling sites and
installations. American state governments should be receiving tax revenues, not
Antigua and the other 84 foreign jurisdictions.
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