Nothing to do with fraudulent Paypal accounts. Anybody can open a Paypal account, all they need is an email address. A premier, verified account requires some verification, but the average buyer would never have to go to that level.

I've only been an eBay member for less than 5 years, but I'm pretty sure digital goods have been a prohibited category ever since I joined.

There is a link at the bottom of every page to the site map. ALL sellers should at least glance at it before selling. And have the odd decko to see if there have been any changes.