31 CFR 103.121 - Federal
regulations requiring the CIP.
In addition, no company may 'export' financial
software to certain countries listed on the
Commerce Control List, which currently
includes Cuba, Iran, Iraq, Libya, North Korea,
Sudan, and Syria.
http://www.access.gpo.gov/bis/ear/pdf/740.pdf
The location and user identity of a download
cannot be reasonably determined during an online
transaction to comply with this export
regulation. All software classified as "payment
software" must ship to a physical address to
comply with export regulations.
Due Diligence is required as cited in
the US Securities Act to determine that
the end user is not an individual that is likely
to commit fraud, launder money, or fund
terrorism.
The Federal Trade Commission (FTC) recently
prosecuted Versa Check Brand, owner of Q-Chex
software for their use of easy to
download payment processing software.
http://www.ftc.gov/opa/2006/10/qchex.shtm
A federal judge ordered "Q-Chex" to cease its current method of online payment processing, which U.S. regulators said facilitated fraud. U.S. District Court for the Southern District of California, alleged that the company's practices violate federal law and successfully obtained an injunction to stop such practices.