oh and as far as fitting the money laundering definition... the feds contend that a law was broken.
If a company accepts a bet from a person located in the State of NY that company is breaking the law. (cite JC's case)
1. Neteller collects money inside the US (ach's company)
2. Neteller sends these funds outside the US (ach company wires $$$ to candian bank)
3. Neteller funnels the funds to offshore book
4. Offshore Book breaks NY law by accepting bet from NY
5. Offshore Book sends Neteller proceeds of illegal act
6. Neteller sends proceeds of the illegal act back to the US