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Representatives of law enforcement agencies, regulatory bodies, and the credit card and gaming industries expressed mixed views regarding the vulnerability of Internet gambling to money laundering. Law enforcement officials said they believed that Internet gambling could potentially be a powerful vehicle for laundering criminal proceeds at the relatively obscure “layering” stage of money laundering. They cited several characteristics of Internet gambling that they believed made it vulnerable to money laundering, including the volume, speed, and international reach of Internet transactions and the offshore locations of Internet gambling sites.

In their view, these characteristics promoted a high level of anonymity and gave rise to complex jurisdictional issues. Law enforcement officials acknowledged the lack of adjudicated cases involving money laundering through Internet gambling sites but cited what they believed to be contributing factors, including the lack of any industry regulations or oversight. Banking and gaming regulatory officials did not view Internet gambling as being particularly susceptible to money laundering, especially when credit cards, which create a transaction record and are subject to relatively low transaction limits, are used for payment. Likewise, credit card and gaming industry officials did not believe Internet gambling posed any particular risks in terms of money laundering.

Gaming industry officials did not believe that Internet gambling was any more or less susceptible to money laundering than other types of electronic commerce and pointed out that, in their view, the financial industry, which is responsible for the payments system, is better suited to monitoring for suspicious activity in the area than the gaming industry itself.

This report makes no recommendations. We provided copies of this report to the Departments of Justice and the Treasury for their comment. DOJ had no comments on it. Treasury provided technical comments, which we incorporated where appropriate.

There have been numerous well-conducted epidemiological studies of the prevalence of sexual problems in the United States, Europe, and globally [8]. These studies have used differing criteria for identifying sexual problems, yet have produced somewhat similar results. Most studies have found that complaints of low desire are the most common female sexual complaint. Studies have also found that complaints of low sexual desire increase with age, relationship duration, number of small children, relationship discord and symptoms of anxiety and depression [9–11]. These studies have been criticized as not distinguishing between sexual problems (transient issues not requiring medical intervention) and sexual dysfunction (persistent, pervasive problems in adaptation requiring medical intervention).

The limitations of epidemiological data in providing estimates of the frequency of sexual dysfunction in the general population can be appreciated by a careful analysis of the most comprehensive studies to date, the Global Study of Sexual Attitudes and Behavior [8]. This study collected data from 27,500 men and women in 29 countries. Sampling techniques had to be modified for some countries such that comparisons of rates across countries is somewhat problematic. The question pertaining to low sexual desire was ‘During the last 12 months have you ever experienced for a period of two months or more when you lacked interest in having sex?’ If the answer was affirmative, the subject was then asked to rate its frequency as occasionally, sometimes or frequently. This study has been quoted as finding that approximately 33% of women in Canada and the United States complained of low sexual desire. However, this number represents an aggregate of all women reporting occasional, periodic and frequent problems with low libido.