In recent years, virtual currencies have gradually become an important tool for payment and settlement in online gambling cases. Compared with traditional bank cards or third-party payments, the payment and settlement model involving virtual currencies on online gambling platforms is more complex in terms of technical implementation and participating entities. Different roles are often embedded in different links of the chain to jointly complete the flow of funds. Different participants usually only come into contact with one of these links.

For example, some technicians are only responsible for the development and maintenance of wallet platforms; others are ordinary cryptocurrency players who inadvertently become people who help launder gambling funds upstream by selling virtual currencies. In this context, it is difficult for the people involved to form a complete understanding of the entire business chain based solely on their specific actions. It is even more difficult to understand why the case handlers regard themselves as a link in providing assistance to gambling websites in opening casinos.

This article combines case-handling experience to sort out the different cooperation models that are more common in practice for providing payment and settlement services to gambling websites using virtual currencies, and restores the connection between various business models from a full-chain perspective. It is hoped that through the introduction of different models, practitioners can more clearly identify such business models, understand the role of each link, and thus make more prudent judgments when facing related businesses and avoid touching legal risks.

Custom Development of Self-Built Systems

Some gambling platforms choose to build their own virtual currency payment and settlement system instead of accessing third-party services. The specific approach is usually to hire programmers or technical teams to develop wallets and settlement modules from scratch and deeply bind them to platform services. The core of this type of system lies in the design of the “collection address”: the platform will assign an independent recharge address to each user. After the user transfers USDT and other funds into it, they are superficially dispersed in different addresses, but in reality, they will eventually be collected into at least a few main wallets controlled by the platform, and then the collection and settlement will be completed automatically or manually in a unified manner.

The reason why gambling websites adopt this method is, on the one hand, out of consideration for the control of funds—the funds are completely in the hands of the platform itself and do not rely on third-party channels; on the other hand, in the case of large transaction volumes, self-built systems can also reduce long-term channel costs and improve flexibility. From a practical point of view, technicians in this model are often deeply involved. Whether it is internal platform developers or outsourcing teams, once the system they develop or maintain is identified as a key infrastructure for fund transfer, it may be regarded as substantial support for the overall business, and thus be included in the scope of accountability in the case.

Cooperation with Wallet Companies

Another common practice is that gambling platforms do not develop their own payment and settlement systems, but instead access the services provided by third-party “wallet companies” through API interfaces. In this model, the platform only needs to complete the interface docking to generate an independent recharge address for each user. After the user transfers virtual currency into it, the relevant on-chain transactions are handled by the service provider in a unified manner, and the platform obtains the transaction confirmation result through the callback interface, and completes the points addition or subsequent settlement process accordingly. Overall, the payment and fund processing links are “outsourced” by the platform to third-party service providers.

The reason why gambling websites adopt this method is mainly out of consideration for efficiency and cost. From a practical point of view, these “wallet companies” are often in a key position in the fund chain. In a current case, a digital wallet company was subjected to cross-provincial arrests of nearly one hundred employees by public security agencies in Hangzhou, Shenzhen, Chengdu, and other places for providing technical services to gambling platforms. It can be seen that even if they do not directly participate in the operation of online gambling platforms, wallet company personnel may be included in the evaluation scope of the overall business due to their role in the technical support link.

It should be noted that the above two models mainly solve the problem of virtual currency receipt and settlement after funds enter the platform, that is, “how money is transferred on the chain.” However, for the platform, it is also necessary to solve: how the gambler’s funds enter the platform, and how the collected virtual currency is ultimately realized. It is in these two front and back links that the following cooperation models are extended.

Cooperation with Running Score Platforms

Another common model is that the platform does not directly handle user funds, but instead entrusts the recharge link to a running score platform. In this model, the gambling platform will push the recharge order to the running score platform, which will organize a large number of “running score customers” to provide personal accounts for collection. Specifically, after the recharge request is distributed, the running score customer collects funds through his/her Alipay, WeChat, or bank card. At the same time, the running score platform then uses its internal virtual currency settlement mechanism to settle the corresponding amount to the upstream platform in the form of USDT.

From the perspective of the fund path, the collection link that should have been directly completed by the platform is split into a large number of decentralized personal accounts, while virtual currency assumes the function of hedging and settlement in the background. The main reason for adopting this method is its highly decentralized nature. From a practical point of view, the number of participants in this model is often large, and the chain is more dispersed. In related cases, this type of behavior is usually included in the evaluation of the fund settlement link.

Cooperation with OTC承兑商

The above-mentioned cooperation between gambling websites and running score platforms solves the problem of how gamblers pay money into the platform. After the funds are collected, the online gambling platform also needs to solve the problem of how to convert the virtual currency in its hands into fiat currency. In this link, they usually cooperate with OTC承兑商. OTC承兑商 are generally individuals or teams specializing in the exchange of fiat currency and virtual currency. The gambling platform hands over the accumulated USDT and other virtual currencies to the承兑商 for processing, who sells them externally through its own transaction network, and returns the corresponding RMB to the platform, thereby realizing the final realization of funds.

In actual operation, this type of entity usually has a certain fund pool and stable trading counterparties, and can continuously provide C2C承兑 services. From the perspective of the business chain, the承兑商 assumes the role of “export”: the funds that enter the system through recharge, diversion, and other methods at the front end ultimately need to be exchanged and withdrawn in this link. This link is often regarded as an important node in the flow of funds, which is why a large number of groups are convicted of helping information network criminal activities and concealing criminal proceeds in practice due to buying and selling virtual currencies.

Conclusion

The above summarizes the four common models of gambling platforms using virtual currencies for payment and settlement. In practice, many people only participate in one specific link, such as some are responsible for writing programs, some do wallet interfaces, some participate in collection, and some are engaged in virtual currency exchange. In their perception, their own behavior should not involve any risk.

However, from the perspective of case handling, when the recharge, flow, and final realization of funds are connected in series, it will be found that this is actually a complete path. Different people are in different positions, each completing one section of it. It is precisely because of this that although the people involved do not directly participate in the specific operation of the gambling website, their behavior may be understood under the same chain in general.

[Wu Blockchain]