I wrote the pokerfuse PRO article, where I stated that "The provisions listed in Article 71 can only be interpreted as creating a segregated player pool."
I live in Peru, so my Spanish isn't rusty
but I queried the precise meaning of the Spanish phrases used in the law and got a legal pair of Peruvian eyes to confirm that it would encompass the random number generation process necessary to deal the virtual cards for online poker.
Having read every bloody Article in the law, and the footnotes, it seems to me that the Spanish and French regulatory models--which both use segregation--are the ones which the text's authors have tried to emulate.
I'll be delighted to be proved wrong, but it seems that the general language of the text allows for very little wiggle room.