Most people in the USA probably don't know this, but in Canada we can do cross-border ACH payment to/from the USA. It costs pennies per transaction, processes the same business day, and it only costs a couple hundred dollars to get it setup.

In terms of the money-related statutes of the USA: we just agree to them by signing a contract with our local bank. If you are found to be in breach of it, you are not arrested or fined. Your bank accounts are simply closed.

This might be a better option for those who want to provide ACH services to US customers. In the likely event of a US government backlash you'd just find your accounts closed. You wouldn't be in a legal battle or end up sitting in the 'clink.

A word of caution: I still wouldn't use ACH to debit from bank accounts. You will have fraud/sore casino losers/etc, and your only remedy is to sue. The banks don't get involved with ACH disputes at all because there is no money in it. (Pennies vs a credit card where the bank charges the merchant $20-$45 to mediate complaints.)

Paying people with ACH doesn't seem to be a problem at all. Actually, it is far cheaper and faster than wires.

I have software that I had written many years ago for a client of mine that actually produces the specially-formatted CPA (Canadian Payments Association; our equivalent of the ABA) files that are uploaded and parsed by our banks in Canada. If someone in Canada (or a US citizen using a trustee in Canada) needs programming examples I can provide them.