According to several posters on poker discussion forums, the following internal GCG memo describes the categories of players who, because of their relationships with FTP, are to be excluded from the refund process. Note that the following likely applies only to American Full Tilt players, since offshore FTP-ers likely were able to access their account balances after Stars purchased the Full Tilt assets and relaunched the site for most of the rest of the world.
The memo body:
The following persons are excluded from the Remission process and are not eligible for payment from the Full Tilt Poker ("FTP") Fund:
i. A past or present employee of FTP or any of its past or present affiliates;
ii. A past or present vendor of FTP that received compensation through FTP players' accounts;
iii. A past or present Team Full Tilt player;
iv. A past or present shareholder of FTP, Tiltware LLC, Kolyma Corporation A.V.V., Pocket Kings Ltd., Pocket Kings Consulting Ltd., Filco Ltd., Vantage Ltd., Ranston Ltd., Mail Media Ltd., or Full Tilt Poker Ltd.;
v. A past or present officer or director of FTP, Tiltware LLC, Kolyma Corporation A.V.V., Pocket Kings Ltd., Pocket Kings Consulting Ltd., Filco Ltd., Vantage Ltd., Ranston Ltd., Mail Media Ltd., or Full Tilt Poker Ltd. or any of their past or present affiliates;
vi. A defendant in any civil action or a claimant in any forfeiture action brought by the Department of Justice related to the violations alleged in this action, or any related action (or any of his or her affiliates, assigns, heirs, distributees, spouses, parents, children, or controlled entities); and
vii. A person who, as of the Petition filing deadline, has been the subject of criminal charges related to the violations alleged in this action, or any related action (or any of his or her affiliates, assigns, heirs, distributees, spouses, parents, children, or controlled entities).Attempts to verify the memo's authenticity went unanswered by GCG, the claims administrator, though one of the people posting GCG's non-denial of authorship was the PPA's Rich Muny, who was also one of several dozen "Friends of Full Tilt" who could be construed as having had a business relationship with the site. (Such "Friends" received rakeback privileges and other courtesies, which could fall into one of the categories above.)
As many as 200 members of Team Full Tilt, Full Tilt Pros and Friends of Full Tilt could be affected, along with untold hundreds of former FTP affiliates, assuming that their affiiliate and/or rakeback payments remained in their online FTP bankrolls as of Black Friday. Full Tilt traditionally paid the funds for its business partners into such player accounts, leaving those players and associated businesses to withdraw funds from the site in a manner of their own choosing.
If the GCG and DOJ choose liberal definitions of "vendor" and "affiliate" that include most of the company's secondary business relationships, then its likely that millions in possible US player claims will be initially denied, categorized as disputed, and left to those players to battle in court with the DOJ over the seized and missing funds.