Reportedly there now are 'normal" and "special" merchant accounts:

> (00:52:52) MagicalTux: we have written consent from Dwolla, basically now Dwolla has "normal" merchant accounts, and "special" merchant accounts with extra requirements

 - http://www.reddit.com/r/Bitcoin/comments/tp0xt/dwolla_changes_tos_to_prohibit_bitcoin/c4ohxsq
 - http://www.reddit.com/r/Bitcoin/comments/tp0xt/dwolla_changes_tos_to_prohibit_bitcoin


tl;dr: Another PayPal is born (in the negative sense):

You understand and agree that you will not engage in the following activities:
- Use the Dwolla system to operate or engage in any business regulated by FinCen, including the money service business;
- Use the Dwolla System without written consent in association with any online credit or virtual currency system;


YOU UNDERSTAND AND AGREE THAT YOU MAY NOT BE ABLE TO ACCESS FUNDS HELD IN THE VERIDIAN HOLDING ACCOUNT IF YOUR USER ACCOUNT IS CLOSED, SUSPENDED, HAS A HOLD PLACED ON IT, OR IS OTHERWISE LIMITED, AS DETAILED IN THIS SECTION.

You understand and agree that the decision by Dwolla to take certain actions, including placing holds on or limiting access to Your User Account as detailed below, may be based on confidential criteria that are essential to risk management or security concerns. You understand and agree that neither Dwolla nor Veridian are under any obligation to disclose the details of its risk management or its security procedures to You.

- Place a Hold on Your User Account for Up to 90 days:
- Temporarily or Permanently Suspend or otherwise Limit Your Access to Your User Account:
- Contact Users who have purchased goods or services from You, contact Your bank or credit card issuer, and/or warn other Users, law enforcement, or impacted third parties of Your actions; or
- Take legal action against you

So I wonder what level of person-to-person transactions with Dwolla before they start freezing accounts.  How do we know which merchant accounts are "special" merchant accounts (and thus allowed) and which are not (and thus risks losing funds)?

Wow.