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Unlawful Internet Gambling Enforcement Act (UIGEA)

The Unlawful Internet Gambling Enforcement Act (“UIGEA” or “the Act”) prohibits anyone in the business of betting or wagering (as defined by the Act) from knowingly accepting payments in connection with unlawful Internet gambling, including payments made through credit cards, electronic funds transfers, and checks. “Unlawful Internet gambling” means placing, receiving, or otherwise knowingly transmitting a bet or wager by any means which involves the use, at least in part, of Internet gambling where such bet or wager is unlawful under any applicable federal or state law in the state or tribal lands in which the bet or wager is initiated, received, or otherwise made. A “restricted transaction” is any transaction in which a person accepts credit, funds, instruments or other proceeds from another person in connection with unlawful Internet gambling. Designated payment systems covered by the Act are (i) automated clearing house (ACH) systems, (ii) card systems, (iii) check collection systems, (iv) money transmitting businesses, and (v) wire transfer systems.

The Department of Treasury and the Federal Reserve Board have issued a joint final rule, Regulation GG, to implement the Act. Regulation GG requires certain participants in payment systems that could be used for unlawful Internet gambling to have policies and procedures reasonably designed to identify and block or otherwise prevent or prohibit the processing of restricted transactions. Banks are required to comply with the Act beginning June 1, 2010.

The Department of Treasury and the Federal Reserve Board require all banks to notify our business customers of this regulation. In accordance with the requirements of the Unlawful Internet Gambling Enforcement Act of 2006 and Regulation GG, we are required to inform you that restricted transactions as described above are prohibited from being processed through any Kenney Bank and Trust account or relationship.

Please contact Joseph Kadolph at 262.432.1549 regarding any questions about this requirement.

The interagency guidance published on May 20, 2010 can also be viewed at www.federalreserve.gov/boarddocs/srletters/2010/sr1011.pdf