Attorney Shao Shiwei | Analyzing Four Models of Online Gambling Platforms Using Virtual Currencies for Settlement: How Technical Personnel, Wallet Companies, and OTC Acceptors Become Implicated in the Crime of Opening a Casino

Custom Development of Self-Built Systems

Some gambling platforms choose to build their own virtual currency payment and settlement systems rather than integrating third-party services. The specific approach usually involves hiring programmers or technical teams to develop wallets and settlement modules from scratch, deeply integrating them with the platform's operations.

The core of such systems lies in the design of "collection addresses": the platform assigns a unique deposit address to each user. After users transfer funds such as USDT to these addresses, although the funds appear scattered across different addresses, they are ultimately aggregated into a few master wallets controlled by the platform. The program then automatically or manually completes the aggregation and settlement.

Gambling websites adopt this method partly due to considerations of control over funds—the funds are entirely held by the platform itself, without relying on third-party channels. On the other hand, in cases of large transaction volumes, self-built systems can reduce long-term channel costs and increase flexibility. Therefore, some platforms establish internal technical teams to develop systems, while others choose to outsource customization to external teams.

From a practical perspective, technical personnel under this model are often deeply involved. Whether they are internal developers of the platform or part of an outsourced team, once the system they develop or maintain is deemed key infrastructure for fund flows, they may be regarded as providing substantial support to the overall business, thus falling within the scope of accountability in the case.

Cooperation with Wallet Companies

Another common practice is for gambling platforms not to develop their own payment and settlement systems, but to integrate services provided by third-party "wallet companies" via API interfaces.

Under this model, the platform only needs to complete the interface integration to generate unique deposit addresses for each user. After users transfer virtual currencies, the service provider uniformly handles the relevant on-chain transactions. The platform obtains transaction confirmation results through callback interfaces and completes the crediting of points or subsequent settlement processes accordingly. Overall, the payment and fund processing links are "outsourced" by the platform to third-party service providers.

Gambling websites adopt this method mainly for reasons of efficiency and cost. Compared with building their own systems, integrating ready-made payment services can significantly shorten the launch cycle and eliminates the need to bear the technical complexities of maintaining blockchain nodes, confirming transactions, and aggregating funds. For platforms lacking technical accumulation or wishing to launch quickly, this is a more convenient choice.

From a practical perspective, such "wallet companies" often occupy a key position in the fund chain. On one hand, their services revolve around the generation, flow, and confirmation of funds; on the other hand, their client structure tends to be somewhat concentrated. Once the relevant platforms are investigated and dealt with, service providers that have cooperated with them long-term or provided technical support are often included in the scope of investigation.

In existing cases, a certain digital wallet company had its personnel arrested across provinces by public security organs in Hangzhou, Shenzhen, Chengdu, and other locations for providing technical services to gambling-involved platforms, resulting in the arrest of nearly 100 employees of the platform. This shows that even if wallet company personnel do not directly participate in the operation of online gambling platforms, they may still be included in the evaluation of the overall business due to their role in the technical support link.

It should be noted that the above two models mainly address the issue of receiving and settling virtual currencies after funds enter the platform, i.e., "how money flows on the chain."

However, for the platform, it must also resolve: how gamblers' funds enter the platform, and how the aggregated virtual currencies are ultimately converted into fiat currency.

It is precisely in these preceding and succeeding links that the following cooperation models emerge.

Cooperation with "Running Points" Platforms

Another common model is where the platform does not directly handle user funds, but delegates the deposit link to "running points" platforms.

Under this model, the gambling platform pushes deposit orders to the "running points" platform, which organizes a large number of "points runners" to provide personal accounts for receiving payments. Specifically, after deposit requests are distributed, the points runners receive funds through their own Alipay, WeChat Pay, or bank cards. Meanwhile, the "running points" platform uses its internal virtual currency settlement mechanism to uniformly settle the corresponding amounts to the upstream platform in the form of USDT, etc.

From the perspective of fund paths, the collection link, which should originally be completed directly by the platform, is split among a large number of dispersed personal accounts, while virtual currencies serve the function of hedging and settlement in the background.

The main reason for adopting this method lies in its highly dispersed nature. Each sum of money corresponds to a different receiving account, causing the overall fund flow to present a fragmented state, thereby increasing the difficulty of identification and tracking to some extent. At the same time, the platform transfers the collection risk, originally concentrated on itself, to the large number of personal accounts involved.

From a practical perspective, the number of participants under this model is often large, and the chain is more dispersed. For the specific points runners involved in receiving payments, although they only handle single or small amounts of funds, they still undertake an important link in the fund flow within the overall structure. In related cases, such conduct is usually included in the evaluation of the fund settlement link.

In publicly reported cases, such as the "First Virtual Currency Case" involving RMB 400 billion handled by the Jingmen Police in Hubei Province, a similar model was used to complete large-scale fund diversion, reflecting to some extent the scaled characteristics of this model in actual operation.

Cooperation with OTC Acceptors

The cooperation between the aforementioned gambling websites and "running points" platforms resolves the issue of how gamblers pay money into the platform.

After the funds are aggregated, online gambling platforms still need to resolve: how to convert the virtual currencies in their possession into fiat currency. In this link, cooperation with OTC acceptors is common.

OTC acceptors are generally individuals or teams specializing in the exchange between fiat currency and virtual currencies. Gambling platforms hand over accumulated virtual currencies such as USDT to acceptors for processing. The acceptors complete external sales through their own trading networks and flow the corresponding Renminbi back to the platform, thereby achieving the final realization of funds.

In actual operation, such entities usually possess a certain capital pool and stable counterparties, allowing them to continuously provide C2C acceptance services. Some may even purchase at fixed ratios, for example, accepting virtual currencies at an agreed discount to earn the spread. This allows the platform to achieve rapid recovery of funds without having to seek buyers themselves.

From the perspective of the business chain, acceptors assume the role of the "exit": funds entering the system through front-end methods such as deposits and diversion ultimately need to complete conversion and exit at this link.

This link is often regarded as an important node in fund flows, which is also the reason why large groups of people are convicted of the crime of aiding information network criminal activities or the crime of concealing or disguising proceeds of crime for buying and selling virtual currencies in practice.

Conclusion

The above outlines four common models used by gambling platforms for payment and settlement using virtual currencies.

In practice, many people only participate in one specific link, such as writing code, developing wallet interfaces, participating in fund collection, or engaging in virtual currency exchange. In their perception, their own actions should not involve any risk.

However, from the perspective of case handling, when the deposit, flow, and final realization of funds are connected, it becomes clear that this is actually a complete path. Different people occupy different positions, each completing a segment of it.

Precisely because of this, although the individuals involved did not directly participate in the specific operations of the gambling website, their actions may be understood within the same chain when viewed as a whole.