When many Web3 job seekers first encounter positions of this type, the job descriptions they see are often presented in a highly appealing manner:

Decentralized blockchain-based games, on-chain fair gaming, automated settlement via smart contracts, and instant USDT settlement may, at first glance, resemble a cutting-edge Web3 game (GameFi) or an innovative project.

However, if one looks past these buzzwords and examines only how money flows, the essence of the business is not complex: users use virtual assets such as USDT and ETH as stakes, select gameplay options on the front end (such as dice, roulette, lotteries, sports betting, etc.), and then write transactions to smart contracts through Web3 libraries; after receiving funds, the smart contract determines wins and losses according to preset “random number + odds rules,” pays out proceeds to winners from the funding pool, and simultaneously deducts service fees for the platform and the house.

What is publicly transparent on-chain is merely the process; the essence remains the organization of online wagering by an unspecified majority of participants on outcomes, with the platform profiting from rake.

In projects of this type, the day-to-day work of programmers often approximates that of casino technical architects:

responsibilities include drafting betting contracts, draw logic, and funding pool management; researching on-chain randomness to ensure apparent fairness; developing various betting interfaces, odds displays, and draw animations; and building back-end data dashboards to track win-loss statistics and agent rebates.

Many technical personnel consider themselves ordinary employees responsible only for writing code, or believe that “technology is neutral.” However, from the perspective of judicial authorities, technical personnel are regarded as key roles providing technical support to casino platforms.

For example, in the EOS project gambling case [Case No.: (2023) Su 09 Xing Zhong 372], the individuals involved developed a gambling platform named BigGame on the EOS blockchain and accepted bets; the technical personnel were responsible for platform product design, smart contract coding, and platform client code development, and were deemed accomplices to the crime of operating a casino. Practice has clearly established that using blockchain and other technologies to establish gambling websites and accepting bets from participants using virtual assets as stakes constitutes “operating a casino” under Article 303, Paragraph 2 of the Criminal Law.

Another category of positions commonly encountered in Web3 job searches are those disguised under the names of digital asset exchanges or contract trading platforms. Job descriptions may state: responsible for developing perpetual contract matching engines, participating in the design of high-concurrency trading systems, and building risk control and forced liquidation mechanisms... If candidates have experience in traditional finance or matching systems, they may easily interpret this as developing a sophisticated financial product.

In reality, however, the platform’s core offering is often high-leverage perpetual contracts. Users bet on whether the price of a certain asset will rise or fall using USDT, with leverage of up to 150x; if the direction is wrong, positions are instantly liquidated to zero, while the platform steadily collects service fees and continuously takes cuts through forced liquidations, clearing, and funding rates.

In Web3 contract projects, programmers often provide underlying support at the “trading engine” level: implementing high-performance matching systems, margin models, and logic for liquidations and forced closures; establishing so-called risk management systems, which are more aimed at preventing platform losses; and coordinating with product design to incorporate copy-trading, agent rebates, partner programs, and other user acquisition and viral growth mechanisms.

Although similar contract businesses may operate legally in certain overseas jurisdictions, Chinese courts have become increasingly clear in their characterization of such activities in published judgments: in most cases, high-leverage contracts are regarded as gambling activities using virtual assets as stakes, making it difficult for related technical, operational, and agency personnel to completely disclaim liability by asserting that they were “merely employees.”

For example, in the CCFOX case [Case No.: (2024) Ji 06 Xing Zhong No. 10], the court held that the virtual currency contract trading provided by the CCFOX platform was characterized by speculation and chance, and was not subject to state regulation; therefore, the CCFOX platform should be deemed a gambling platform. Shen, as a technical developer for the CCFOX website, was responsible for functional development and providing technical services to the website, and was adjudged an accessory to the crime of operating a casino.

There is another category of positions in Web3 job hunting that appear more sophisticated, involving so-called prediction markets, event contracts, and price prediction games. Such platforms often employ flashy narratives:

"Aggregating collective wisdom through market prices," "predicting the future through trading," and "assetizing all events"... These sound like financial experiments.

However, if you actually examine the gameplay on the official website, you will find that the core logic remains the same: The platform launches bets on whether a cryptocurrency price will reach a certain level on a specific date, or whether certain macroeconomic events will occur (such as the possibility of Trump being impeached again before the end of 2026, when the Federal Reserve will cut interest rates, or when the Russia-Ukraine conflict will end). Users bet "yes" or "no," "rise" or "fall" using virtual assets. Upon expiration, the platform or an oracle determines the outcome, distributes payouts according to the odds, and the platform takes a commission. This is substantively no different from binary options or betting on high/low outcomes; it is merely cloaked in the guise of a "prediction market."

Technical roles are often packaged as highly technical: designing the mechanisms of prediction contracts, implementing contract logic for event creation, betting, and expiration settlement, integrating oracles, and managing arbitration systems... However, what you are actually doing remains fund pool management, odds curve design, and settlement rule formulation. From a judicial perspective, this constitutes a complete set of casino rules centered on "betting on outcomes and distributing gambling proceeds."

In light of the spirit of Guiding Case No. 146 issued by the Supreme People's Court, the gameplay of such prediction markets is not fundamentally different from traditional "betting on high/low or winning/losing." Projects that technicians consider "financial innovation" are, in domestic judicial practice, highly likely to be evaluated and handled as having the nature of gambling.

The final category is one where many Web3 job seekers are most likely to let their guard down, yet it carries extremely high criminal risk: providing the underlying payment systems for deposits, withdrawals, and conversions for gambling pools (i.e., gambling platforms or betting websites).

Some companies often package themselves externally as payment technology firms, clearing and settlement platforms, or fourth-party payment providers, highlighting keywords such as aggregated payment, cross-border settlement, and USDT payment gateways; internally, the team describes itself as a "USDT payment solution or wallet service provider."

If you only look at the job content, it may seem like you are simply integrating various payment channels and wallets, which appears to be normal business. However, the actual business model is often:

• Packaging legitimate payment instruments such as Alipay, WeChat Pay, and bank cards into an "aggregated channel," and then connecting them to overseas gambling websites;

• or using USDT, in-game currency, or points as intermediaries to facilitate two-way conversion between RMB and chips for players;

• and then laundering the funds through multiple layers of accounts, channels, or intermediary wallets.

In such companies, programmers’ daily work often focuses on:

developing deposit/withdrawal systems, integrating interfaces between fiat currencies and on-chain wallets, coding the conversion logic between currencies and chips, building backend systems for transaction records and clearing and settlement, and even optimizing “approval rates” and reducing risk-control interceptions.

However, from the perspective of criminal justice, these activities are typically summarized in one sentence: “providing fund settlement and redemption services for gambling websites.” For example, in the cross-provincial arrest case involving employees of a Web3 wallet company previously discussed by Attorney Shao (➡️ “Reflections on the Cross-Provincial Arrest of a Web3 Programmer: Three Major Legal Blind Spots for Practitioners”), the team to which the individual belonged was investigated because some of its partner merchants were suspected of operating online casinos, resulting in employees being taken away for investigation.

In light of the four common types of gambling platforms described above, Attorney Shao offers the following core advice to Web3 job seekers:

First, firmly keep in mind a red line: if the essence of the business is that “people bet money on outcomes, and the platform profits through odds or leverage-based commissions,” regardless of whether it is labeled as contracts, GameFi, prediction markets, or payment technology, it will most likely be treated as a gambling-related project in judicial practice.

When seeking employment, you can assess risks using the “two-step self-assessment method”:

First, examine the platform’s overall model (look at the big picture): carefully study the project’s whitepaper, official website descriptions, and product mechanics. If the overall logic resembles the Web3 gambling platforms, contract betting schemes, or betting payment channels described earlier, exercise heightened caution and carefully consider whether to accept employment.

Re-examine your job responsibilities in detail: Clarify whether the functions you are actually responsible for involve high-risk areas such as betting logic, draw rules, odds models, forced liquidation mechanisms, deposits and withdrawals, credit/debit operations, or fund clearing and settlement. If you are deeply involved in these areas, it will be difficult to disclaim liability by merely stating, "I only wrote code."

If risks can be identified in advance and invitations decisively declined, criminal implication can often be avoided. Once entangled in such projects, job seekers often face not merely the need to "find another job," but the dual costs of restricted personal freedom and interrupted career trajectories.