When the law was signed on October 13, 2006, I wrote a thread on the potential loss of bank transfers following the 270 period. Let's agree to disagree at this time and see what happens in the future and rediscuss this issue down the line. Time will tell us whether or not the banks conform to the law.
OMT - I think it would be helpful in light of this thread to explain how a bankwire actually works - something most dont know but should.
The bankwire system is archaic. Every country does its own thing, and only in the last 20 years have there been efforts to unify the procedures, but there still are many unique flaws. The first one is that there are no tracking numbers, so you kind of send it and hope.
The IBAN number is the key to the routing of the funds. The IBAN number contains all of the pertinent information on an international wire, and the numbers imbedded in it are often duplicated elsewhere on the wire. Here is a key to the IBAN number:
If you look at the IBAN number, it contains a lot of information:
AABB CCCC DDDD DDEE EEEE EE
A = Country Code
B = Mathematically generated check digit (not intelligent info)
C = Bank Alpha Code
D = Sort Code
E = Account Number
If you go back and look at any wire instructions, they give you the IBAN number and also give you the bank, sort code, and account numbers even though they are already imbedded in the IBAN.
If you have the IBAN, the money gets routed to the account number that is the last 8 digits. The key to this whole thing, and the reason banks fought this bill so hard, is that the account number listed is the account number of the BANK.
To explain that - the money goes through one of a handfull of huge clearing house banks - and then goes in to an account number of the beneficiary bank. So in other words, the bank in the caribbean that you are sending the money to is an account holder at the big clearing house bank. The bankwire instructions end when the beneficiary bank has your money.
How does the beneficiary bank know who's funds and what account at their bank to credit? By the "special instructions" field.
So when you think about this it is incredibly archaic, and not so different from a WU transfer. The name you put on a WU transfer is not critical to the transfer or the routing of the funds, it is the "special instructions" on your bank wire.
So now to your solution of maintaining a list of banned gambling accounts. How would they do this>? The second one got banned, all the sportsbook would do is change the "special instructions" to say anything they wanted, and something their bank knew was them, and you have essentially changed the name from "tom jones" to "bill harris".
This is why the banks fought the bill so hard. The bill imposes criminal liability on employees who have absolutely no way to enforce this under the current bankwire system. And this is why it is my opinion that there is no time in the near future that the whole world will change the worldwide bankwire system to accommodate online gambling legislation in the US.
It is very hard (impossible) to suggest a system that could work using the current bankwire model.
