If the funds are simply "from internet gambling", you could argue that it represents affiliate payments, not actual money from a casino account. This might work since it is not illegal to work in the industry, only illegal to promote the activity to US players, or transact for the purpose of placing wagers.
To prosecute, it would have to be proven that the funds were the result of successful wagers on your part, rather than affiliate payments for operating a website that has brought non-US players to a casino.
It is pretty easy to set up an affiliate site and promote a few casinos to the non-US market (just in case you are asked to back the story up with evidence). You will have to pay tax on the payments, but since winnings are taxable anyway, hardly a loss to the US player. Your deductable "costs" are the money that went the other way.
This may be enough to make the bank feel that a warning "shot across the bows" is enough in the case of individual account holders, rather than getting mired in such a debate during any investigation.
In fact, pursuing individual players could backfire in the same way that the RIAA suffered when it took "grandma" to court and sued for several million dollars.
Investigation may really be about shutting down the pathways for the future, rather than sending players to jail for past actions.
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