Based in Washington, DC, The Center for Regulatory Effectiveness (CRE) is headed by former Office of Management and Budget (OMB) executives who issued the report in response to the Government’s proposed regulations. UIGEA seeks to disrupt financial transactions with online gambling companies but CRE stated that the Treasury had not provided objective or supported estimates of the burden that the proposed regulations could have on groups such as small businesses, something required by the Paperwork Reduction Act.

CRE also criticised the lack of clarity on what gambling transactions would be permissible and stated that UIGEA would increase the burden on companies required to enforce the regulations.

'The agencies have declined to state which Internet gambling transaction are unlawful and have recognized the difficulty of doing so for reasons including 'the fact that the legality of a particular Internet gambling transaction might change depending on the location of the gambler at the time the transaction was initiated and the location where the bet or wager was received’,' read the CRE report.

'Without such a determination, which underlies all identification and blocking tasks, the entire set of policies and procedures would be useless, lack practical utility and, thus, could not be approved by OMB.'