This is my understanding, as well.
The anti-gambling/anti-poker laws from "Black Friday" in 2011 actually have to do with banking and USD.
This is why there are actually several US-facing card rooms operating out of country semi-legally - they do not do banking in the US, so they are not afoul of laws in most states. I believe New York is a notable exception along with a few other states which sites like Bovada will not accept US users from.