I disagree. Affiliates may be the low hanging fruit, but going after affiliates doesn't make sense for a number couple of reasons:In a lot of cases - you the affiliate marketer are a much more attractive of a legal target.
1. If its money the government is going after, the affiliates have the least of it.
2. The affiliates aren't the ones realizing the financial transaction. If [as an affiliate] I sell a gun to someone, and that person goes out and murders somebody, you can't come after me due to someone else's actions.
That said, the alphabet boys have a lot more to gain by getting as close to the source as possible; if they can't go after the offshore partnerships, they can go after the CC processing merchants or the entities within the US that do business with the company in questions.
Either way, the advertisers have a responsibility to ensure the parties they choose to do business with - the networks - are in full legal compliance. From there, the networks have the responsibility to ensure that whoever they do business with 2nd tier networks and affiliates are in compliance.
Obviously you're familiar with regulation in the mobile industry; it comes from the top down, not bottom up.