PAGE 1

TABLE OF CONTENTS

FOREWORD

EXECUTIVE SUMMARY 4

BACKGROUND 5

I. INTRODUCTION 6

II. AN OVERVIEW ILLEGAL BETTING AND GAMBLING MARKETS IN INDIA 9

III. PART I: ILLEGAL MARKETS IN INDIA - WHO ARE THE ENABLERS? 14

DIGITAL ADVERTISING 15

PAYMENTS ECOSYSTEM 23

IV. PART II: ENFORCEMENT MEASURES AROUND THE WORLD- A SCOPING REVIEW 27

V. RECOMMENDATIONS 32

VI. ANNEXURES

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FOREWORD

The digital landscape is evolving rapidly, shaping industries, economies, and even electoral processes. The
2024 super year of elections reinforced how technology, social media, and parallel markets are increasingly
intertwined, bringing both opportunities and risks.

As we examine these trends, we recognize that one of the most pressing challenges is the rise of illegal
operators in gambling and betting, which raises concerns about financial fraud, consumer protection, and
the broader implications for governance. Their ability to exploit digital advertising, payment networks, and
offshore jurisdictions highlights the need for a more coordinated enforcement approach.

Our report provides a timely analysis of the illegal gaming ecosystem, mapping its enablers and examining
global enforcement strategies. By analyzing their impact on financial integrity and regulatory enforcement,
the report highlights the need for a comprehensive approach to tackle this issue.

I appreciate the efforts of the DIF team for engaging stakeholders. I hope the report adds to important
discussions , and serves as a valuable resource for policymakers, industry leaders, and stakeholders
working towards a stronger digital economy.

Dr. Arvind Gupta

Founder, Digital India Foundation

PAGE 3
EXECUTIVE SUMMARY

● Illegal betting and gambling operators have rapidly expanded their footprint in India. In 2023, the
Parliamentary Standing Committee on Finance identified online betting sites as a key enabler of
money laundering and terror financing.
● Despite repeated government actions, including website blocking and advisories, illegal operators
continue to thrive, using advanced digital marketing tactics, seamless payment processing, and
mirror websites to evade enforcement.
● The scale of illegal gambling and betting in India is immense, with 1.6 billion visits recorded in just
three months across the four analysed platforms—Parimatch, Stake, 1xBet, and Batery Bet.
● Notably, each operator maintains multiple mirror websites to circumvent regulatory takedowns.
For instance, just three Parimatch mirrors alone generated an additional 266 million visits,
suggesting the true scale of the illegal market is significantly higher than anticipated.
● Further, Google Search trends from February 2021 to December 2024 revealed an exponential rise
in searches for Dafabet, 1xBet, Parimatch, 4rabet, and Khelo24Bet, with major spikes observed
during Indian Premier League seasons (March - April) in 2021, 2022, 2023, and 2024.
● Illegal operators sustain their operations through a highly sophisticated network of enablers of
Digital Advertising and Marketing Channels, Payment Ecosystem, and Software Providers.
● In Digital advertising:
a. Social media drove ~42.8 million visits to the four illegal operators in three months.
b. Organic search traffic accounted for ~184 million visits, driven by high-ranking search results.
c. Referral traffic generated ~247.5 million visits, primarily from adult sites, gambling affiliates
and promotions on sports and video streaming platforms.
d. 1.098 billion visits to illegal platforms originated from users directly entering URLs—
indicating success of past marketing efforts, referrals etc.
● While major digital platforms prohibit betting and gambling-related promotions, enforcement is
highly inconsistent. Advertisements on Facebook Ad Network have grown exponentially in recent
years.
● Illegal operators offer a range of payment options, including UPI transactions facilitated through
mule accounts, cryptocurrencies, and international wallets like AstroPay.
● Some payment service providers appear to have implemented technical tools to detect high-risk
transactions, issuing warnings to users attempting payments on these platforms. However,
enforcement remains inconsistent.
● Experience from multiple jurisdictions including Norway, UK, Denmark, Belgium, and the United
States shows that blocking alone is ineffective. Countries that combine website blocking with
marketing restrictions for illegal betting and gambling, payment blocking, and whitelisting/blocking
have achieved greater success.
● Therefore, India must shift from the current fragmented enforcement strategy to a comprehensive
ecosystem-based approach that effectively disrupts the key enablers sustaining illegal betting and
gambling operations. This includes curbing digital media channels that drive user acquisition for
these platforms, tightening financial regulations to block illicit transactions, and enhancing
enforcement mechanisms via a whitelist/blocklist to sustain long-term disruption.
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BACKGROUND

The year 2024 was significant for global democracy, with elections across 72 countries involving nearly 3.7
billion voters. The increasing influence of digital technologies on electoral processes was a key theme in
this super-election year, with three dominant trends shaping campaigns and outcomes: the use of AI and
technology, the rise of influencers and social media, and the emergence of parallel digital markets.

While technology helped campaigns reach voters more effectively, it also enabled the spread of
misinformation. The Parallel digital market, particularly offshore betting and gambling platforms, have
raised serious concerns about unregulated financial flows and electoral integrity. Meanwhile, social media
influencers became increasingly important in political discussions, raising questions about authenticity and
paid promotions.

Among these, the rise of illegal operators in the gaming ecosystem has emerged as a pressing concern,
having increasingly exploited digital advertising, social media, and alternative payment networks to evade
detection. These platforms not only facilitate large-scale financial crimes but also create vulnerabilities in
election financing by enabling opaque transactions, money laundering, and cross-border fund transfers.
The Parliamentary Standing Committee on Finance and enforcement agencies have highlighted the
growing risks posed by these networks, underscoring the urgent need for regulatory interventions.

This report builds upon these insights by focusing specifically on the ecosystem of illegal gaming operators
and their enablers. It examines how these platforms exploit digital advertising, social media, and payment
networks to evade detection, and it reviews global enforcement strategies to disrupt their operations. By
mapping the regulatory gaps and policy challenges, this study aims to inform a more comprehensive
response to mitigate the risks posed by illegal betting markets and their impact on India’s digital economy.

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I. INTRODUCTION

In recent years, illegal offshore operators have turned India into a major hub for betting and gambling
activities. Recognising the growing threat, the Parliamentary Standing Committee on Finance, in its July
2023 report titled ‘Cyber Security and Rising Incidence of Cyber/White Collar Crimes,’ highlighted four
major trends shaping the cybercrime landscape:1

“The first one is the use of crypto for money laundering and terror financing. The second is the use of
mule accounts with false addresses. That is the second typology. The third typology is the use of
international online betting sites both for the purpose of money laundering and terror financing. The
fourth trend we have seen is the lending apps and apps for investments which have been used and
which have been caught in the system. So, these four typologies have been primarily reported [sic] as
regards the mule account, it is mostly in India. But in the three other instances, the offshore entities are
involved. It may be crypto. It may be the online betting sites. There is a clear set of online betting sites
which are based out of tax havens.”

In the same report, the Financial Intelligence Unit (‘FIU’) highlighted several key suspected money
laundering and terrorist financing trends, typologies, and developments, including those relating to
offshore online gambling and betting companies, primarily registered in jurisdictions such as Curaçao,
Malta, and Cyprus. An analysis of financial transactions linked to these entities revealed that funds were
collected from individuals under false pretenses, funneled to select individuals and entities—mostly based
overseas—and subsequently used for cryptocurrency purchases.

While the official statistics remain unavailable, one independent report estimates that deposits in illegal
gambling and betting in India exceed USD 100 billion/year.2 This figure is projected to grow at a rate of 30%
per year, driven by increasing digital adoption, technological advancements, and regulatory uncertainty.3

The government has attempted to curb these activities through website blocking and official advisories.
However, these fragmented measures have largely proven ineffective, as illegal operators continue to
function with impunity, constantly adapting to evade enforcement.

The vast scale and resilience of these markets underscore that the illegal gambling and betting ecosystem
in India operates through a sophisticated network of mechanisms that ensure its reach and functionality.
As highlighted by the United Nations Office on Drugs and Crime (‘UNODC’), payments technologies such as
cryptocurrency, social media and messaging platforms are playing a significant role in the globalisation of
illicit activities, including illegal betting.4 Social media platforms are mostly used for discussions and
promotions of services and initial contacts, while messaging platforms are used for private peer-to-peer
communication, invite-only group discussions and real-time betting. The use of cryptocurrencies and

1
“Cyber Security and Rising Incidence of Cyber/White Collar Crimes,” Fifty Ninth Report, Standing Committee on Finance (2022-2023), July 27, 2023,
https://sansad.in/getFile/lsscommittee/Finance/17_Finance_59.pdf?source=loksabhadocs.
2
“State of Betting & Gambling in India,” Think Change Forum, 2024.
3
Id.
4
Section 9: Illegal Betting and Sport, “Global Report on Corruption in Sports,” United Nations Office on Drugs and Crime (UNODC) (2021),
https://www.unodc.org/documents/corruption/Publications/2022/Global_Report_on_Corruption_in_Sport_Chapter_9.pdf.
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cryptocurrency mixing services in the context of illegal betting are also an emerging issue since they offer a
reliable and almost untraceable international money transfer mechanism.

Similar alarming trends are visible in the Indian ecosystem:

a. Use of Mules by Overseas Betting Operators: According to RBI data (July 2024), mule channels
funnel over INR 2,500 crore (~USD 300 million) in illicit funds every month, with law enforcement
recovering only 10% of this amount.5 A report by The Ken exposed the growing trend of ‘mule-as-a-
service,’ revealing that overseas betting and gambling platforms are among the biggest
beneficiaries.6 This suggests that a significant portion of the USD 300 million in illicit funds is being
funneled into offshore illegal betting and gambling platforms, enabling them to evade financial
regulations and sustain their operations without interruption.

b. Tax Evasion: In the Winter Session of Parliament last year, the government reported that no
offshore online gaming platforms had registered with the GST department as required since
October 1, 2023.7 Furthermore, Directorate General of GST Intelligence’s (‘DGGI’) Annual Report
2023-24, Trends in Tax Evasion, revealed that 658 offshore entities were identified as unregistered
or non-compliant, prompting investigations into their activities.8

c. Aggressive Advertisements on Digital Media to Lure Users: According to ASCI’s Half-Yearly Report
for 2024-25, illegal betting and gambling advertisements have surged across digital media in new
formats.9 In response, ASCI flagged 890 such ads to the Ministry of Information and Broadcasting
for further action. Among them, 831 Instagram posts featured betting tickers, redirecting users to
offshore betting platforms. These tags and tickers frequently appear on fan and community pages,
with some page owners reportedly earning between INR 2,000 and INR 3,000 per day for displaying
these logos. Additionally, 50 websites and social media pages were found promoting illegal betting
apps and platforms, while nine influencer posts were identified endorsing such services.

 Reframing the Approach to Combat Illegal Betting and Gambling

In light of the above, this report argues that isolated measures, such as blocking the websites of illegal
betting and gambling operators and advisories, are insufficient to address the vast policy challenges posed
by this growing market. Instead, a more comprehensive strategy is needed—one that targets the entire
ecosystem enabling operations of illegal betting and gambling. This includes cracking down on user
acquisition methods through advertising, payment operators that facilitate deposits and withdrawals, and
software providers supporting these platforms.

To this end, the report is structured into three key sections,

5
“A Rs 2,500 cr scam powered by mule accounts: an illustrated guide,” The Ken, October 29, 2024, https://the-ken.com/story/a-rs-2500-cr-scam-powered-by-
mule-accounts-an-illustrated-guide/.
6
Id.
7
“No offshore gambling companies registered under new GST law so far: Govt in Rajya Sabha,” Gateway to Gaming, December 5, 2023, https://g2g.news/gst-
on-online-gaming/no-offshore-gambling-companies-registered-under-new-gst-law-so-far-govt-in-rajya-sabha/.
8
“More than 650 offshore gaming companies evade GST: Report,” THe New Indian Express, September 16, 2024,
https://www.newindianexpress.com/business/2024/Sep/16/more-than-650-offshore-gaming-companies-evade-gst-report.
9
“Half Yearly Complaints Report 2024-25,” ASCI, November 2024, https://www.ascionline.in/wp-content/uploads/2024/11/Half-Yearly-Complaints-Report-
2024-25.pdf.
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 - Scale and Volume of Illegal Betting and Gambling in India
The first section utilises analytical tools to assess the scale of illegal betting and gambling
operations to understand their digital footprint.

- Key Enablers Driving Growth

The second section identifies and analyses the ecosystem enabling the expansion of illegal
operators, with a focus on advertising and payment networks. It explores how digital advertising
strategies help these platforms acquire users and how financial intermediaries facilitate deposits
and withdrawals, sustaining their operations.

- Global Enforcement Mechanisms

A scoping review of enforcement strategies employed worldwide to curb illegal betting and
gambling. This section evaluates different policy measures, drawing lessons that could inform
India’s approach.

The report concludes that a comprehensive, ecosystem-based strategy is essential—one that disrupts the
entire chain of enablers, from advertising and financial transactions to platform infrastructure and digital
presence. It underscores the need for a coordinated policy response, leveraging global best practices to
develop a robust enforcement framework in India.

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II. AN OVERVIEW OF ILLEGAL BETTING AND GAMBLING MARKETS IN INDIA

2.1 DEFINING ILLEGAL BETTING AND GAMBLING MARKET

Integral to understanding the illegal betting and gambling market is its definition, which, in common with
other transnational crimes, is not consistent or universally agreed upon. The various definitions put forth
indicate that this is a complex and heterogeneous phenomenon.10
Defining this market poses intricate challenges due to several methodological complexities. One major
hurdle is the illegal betting and gambling market encompasses a wide range of practices, including sports
betting, underground lotteries, among others.11 Secondly, there is substantial regional variability due to
differences in gambling laws and cultural norms across countries and even within individual countries.12
Furthermore, the evolution of technologies, particularly the advent of the internet and online gambling
platforms, has significantly altered illegal gambling practices,13 necessitating adaptation in estimation
methods to remain relevant. This transformation is marked by the unprecedented accessibility and
anonymity afforded by online platforms, which have facilitated the proliferation of illicit gambling activities
across various demographics and geographical regions.
In 2014, the Council of Europe made an attempt to formalise the definition in the Macolin Convention (i.e.,
The Convention on the Manipulation of Sports Competitions) by proposing the following definition:14
“illegal sports betting means any sports betting activity whose type or operator is not allowed under
the applicable law of the jurisdiction where the consumer is located”
Interestingly, several studies attempted to expand this definition by incorporating a number of specific
activities that constitute the operationalisation of these illegal betting and gambling markets.
Further, in order to bring more clarity to the definition of illegal betting and gambling, UNODC
recommended the following categorisations:15
a. White market: Operators licensed to operate in all jurisdictions in which they operate.
b. Grey market: Operators licensed in at least one jurisdiction but operate in areas where the
betting/gambling product is illegal.
c. Black market: Operators not licensed anywhere but operate in multiple jurisdictions.

According to the UNODC, illicit transactions occur in both grey and black markets, with grey market
operators often functioning under ambiguous licensing frameworks. Over the past two to three decades,
some jurisdictions have introduced licensing systems that allow online betting and gambling operators to
obtain permits, which many use to legitimise their cross-border activities.

10
Julien Chopin, Lucas Tosi Rodriguez, and Stefano Caneppele, “Defining and Estimating the Illegal Gambling Market: A Scoping Review,” Journal of Economic
Criminology (2024), 100068, https://doi.org/10.1016/j.jeconc.2024.100068.
11
Id.
12
Sean Mackey-Simpkin, “Illegal Gambling in Canada,” [Bachelor Thesis, University of Lethbridge], Department of Psychology, University of Lethbridge (2021),
https://opus.uleth.ca/server/api/core/bitstreams/6ebacf39-40a2-4afc-8d76-299a7be02396/content.
13
Sinyong Choi, “An Examination of Interactions of U.S. Players with Offshore Gambling Sites and Online Casino Reviews: Are They Offenders or Victims?,” PhD
diss., University of Nevada, Las Vegas (2022), http://dx.doi.org/10.34917/31813265.
14
“Convention on the Manipulation of Sports Competitions,” Council of Europe,
https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000016801cdd7e.
15
Section 9: Illegal Betting and Sport, “Global Report on Corruption in Sports,” United Nations Office on Drugs and Crime (UNODC) (2021),
https://www.unodc.org/documents/corruption/Publications/2022/Global_Report_on_Corruption_in_Sport_Chapter_9.pdf.
PAGE 9
The UNODC emphasises, “this situation illustrates why the regulation of internet-based betting & gambling
requires a cross-State approach in order to be effective. With so many online operators in multiple
jurisdictions, it is increasingly difficult to determine which are legal and which are not, except from the
narrow position of whether the operator is licensed in the jurisdiction where the point of sale takes place.”16
For the purposes of this report, we consider the illegal online betting and gambling market (hereinafter
referred to as “illegal market” or “illegal betting and gambling market”) as any betting or gambling
operations that are conducted online in violation of the applicable laws and regulations of a particular
jurisdiction. This market encompasses various forms of activities, such as betting, sports wagering, and
other games of chance, which are conducted without the proper licenses or permits, or in defiance of
established local laws.
This report focuses exclusively on the online illegal betting and gambling market. While illegal activities
also occur in physical spaces, their examination falls outside the scope of this study.

2.2 SCALE OF ILLEGAL BETTING AND GAMBLING MARKET IN INDIA

Quantifying this market poses challenges due to several methodological intricacies – the biggest hurdle is
the acquisition of reliable data, as illegal activities often circumvent conventional data collection systems.17
Furthermore, as previously discussed, the illegal betting and gambling market encompasses a diverse range
of activities and varies significantly across regions.18 Despite its complexities, this task is essential
considering the multifaceted issues associated with this criminal phenomenon.

To date, the most authoritative report on the subject is the 2021 Global Report on Corruption in Sport by
the UNODC, which estimates that the amount wagered on illegal betting markets is between USD 340
billion and USD 1.7 trillion.19

Due to the limited availability of data in India, we conducted a primary analysis to gain a deeper
understanding of the scale and volume of the illegal gambling and betting market.

 SCALE AND VOLUME

Methodology: We analysed web traffic20 for four illegal betting and gambling platforms, along with their
associated mirror websites, over a three-month period from October to December 2024.21

Selected Operators: Parimatch, Stake, 1xBet, and Batery Bet.

SimilarWeb22 provides both global and country-specific traffic data. However, due to certain limitations, we
did not have direct access to an India-specific filter. To overcome this, we selected a mirror website for

16
Id.
17
“Review of Illegal Offshore Wagering: Report to the Ministers for Social Services and the Minister for Communication and the Arts,” Barry O’Farrell, December
18, 2015, https://www.dss.gov.au/system/files/resources/review_of_illegal_offshore_wagering_18_december_2015.pdf.
18
Sean Mackey-Simpkin, “Illegal Gambling in Canada,” [Bachelor Thesis, University of Lethbridge], Department of Psychology, University of Lethbridge (2021),
https://opus.uleth.ca/server/api/core/bitstreams/6ebacf39-40a2-4afc-8d76-299a7be02396/content.
19
Section 9: Illegal Betting and Sport, “Global Report on Corruption in Sports,” United Nations Office on Drugs and Crime (UNODC) (2021),
https://www.unodc.org/documents/corruption/Publications/2022/Global_Report_on_Corruption_in_Sport_Chapter_9.pdf.
20
Web traffic refers to the volume of user visits recorded on the respective platform’s websites.
21
There are, however, certain limitations: the data analysed in this case study only covers traffic generated via browsers—both desktop and mobile. It does not
include traffic from mobile apps. As a result, while mobile-first channels are likely driving sizable traffic to these illegal operators, they fall outside the scope of
this analysis. The present analysis is also subject to other limitations, as it does not account for traffic originating from APK downloads, VPN usage, or other
alternative access methods.
22
A widely used web analytics tool that provides in-depth insights into website traffic patterns.
PAGE 10
each operator. Since these operators frequently use multiple mirror websites to circumvent regulatory
restrictions, we applied a two-step approach to select the most relevant mirror site for each operator:

a. India-Focused Traffic: We selected a mirror website for each operator where at least 97% of the
traffic originated from India. This ensured that the site primarily catered to Indian users.

b. Highest Traffic Mirror: Among the available mirror sites that met the first criterion, we selected the
one with the highest overall traffic, ensuring a representative sample of user activity.

While this approach does not capture the full extent of traffic for each operator across all their mirror sites,
it provides a reliable estimate of traffic directed to at least one major mirror per operator. Based on this
methodology, the selected mirror websites were:

a. pari-match-in.com (Parimatch): 99.86% traffic from India

b. stake.bet (Stake): 97.07%
c. 1xbetind.in (1xBet): 99.85%
d. batery-bet.in (Batery Bet): 99.76%

Key findings:

Total Traffic b/w October and December 2024 (in millions)

● Total visits to the analysed illegal
Domain Traffic platforms ~ 1.6 Billion in 3 months.

● The actual numbers are likely much

pari-match-in.com 1223 M higher, as this analysis excludes traffic
from APK files, VPN usage, and other
alternative access methods.
stake.bet 211.2 M
● High traffic to illegal operators, despite
website blocking measures, suggest that
1xbetind.in 79.28 M
this enforcement strategy has been
largely ineffective.
batery-bet.in 118.2 M

Total 1632 M

 What is the growth trend like since 2021?

To evaluate the growth trajectory of illegal betting, we analysed Google Search trends for Dafabet, 1xBet,
Parimatch, 4rabet, and Khelo24Bet from February 2021 to December 2024. Search trend data serves as a
critical indicator of the prevalence, seasonal spikes, and overall popularity of these platforms within the
digital ecosystem.

Our analysis revealed a sharp and exponential rise in searches for these betting websites, particularly since
October 2023, highlighting a significant surge in user interest and engagement. This trend suggests

PAGE 11
increasing market penetration, potentially driven by aggressive marketing strategies, and expanded user
outreach.

In addition to this, illegal betting activity peaked during the Indian Premier League (‘IPL’) season (April ‘21
April ‘22, April ‘23, April ‘24), reflecting heightened market activity during this period. Understanding these
seasonal patterns is crucial for regulators and enforcement agencies, as it enables them to implement
timely interventions and preventive measures during high-risk periods. If specific events—such as the IPL
or international cricket tournaments—consistently trigger search surges, targeted policy responses and
awareness campaigns can be deployed to mitigate the potential risks associated with increased betting
activity.

In
Millions

Figure 1: Google Search Trends results for Dafabet, 1xBet, Parimatch, 4rabet, and Khelo24Bet from February 2021 to
December 2024 in Millions.

 Hidden Scale of Illegal Betting and Gambling: Mirror Websites

The data and analysis above highlight the significant role that multiple digital channels play in driving traffic
to illegal betting and gambling operators. However, it is essential to emphasise that the findings presented
only account for a single major mirror website of each operator. These operators maintain multiple mirror
websites, which operate in parallel, with some becoming more active during specific periods.

To illustrate this, we analysed four mirror websites of Parimatch, including the primary one used in the
earlier analysis. As before, we selected mirror websites where at least 99% of the traffic originated from
India during October - December ‘24:

a. pari-match-in.com: 99.86% traffic from India with 1.223 Billion traffic

b. win.pari-match-in.com: 99.86% from India with 1.194 Billion traffic
c. pari-bet.in: 99.65% traffic from India with 151 Million traffic
PAGE 12
 d. pari-matchin.com: 99.72% traffic from India with 115 Million traffic

Moreover, during account creation, we discovered that the same login credentials worked across multiple
mirror sites. For instance, an account registered on pari-matchin.com was also valid on pari-match-in.com.
This seamless access ensures continuity even if a mirror is taken down, reinforcing user trust and retention.

These findings underscore a crucial reality: illegal gambling and betting operators rely on a vast network of
mirror websites, each attracting hundreds of millions of visits each quarter. As a result, the true scale of
their operations and footprint in the Indian market is significantly larger than it appears on the surface.

2.3 POTENTIAL REASONS FOR HIGH VOLUME

A study highlights that when black market operators market their products on a relatively level-playing
field with legitimate operators, a leakage of 2-3% is almost inevitable.23 This is largely due to the sheer
scale of the black market: globally, there are over 4,000 gambling operators, whereas Britain, despite being
the largest licensing jurisdiction by the number of operators, has only 200 active online licensees at the
group level. In such a scenario, customers are statistically more likely to encounter an illegal site than a
legitimate one.

The only mitigating factors are intangible benefits such as brand reputation and trust, which offer some
resistance. However, the effectiveness of these benefits depends on the ease of access to black market
sites. If there are no “frictions” or barriers (such as legal enforcement, payment restrictions, or penalties)
to discourage users from using black market sites, even the trust and reputation of legitimate operators
may not be enough to prevent some users from shifting to illegal options. Essentially, without external
deterrents, the inherent advantages of legitimate operators can only provide limited resistance against
black market competition.

The illegal betting and gambling operators in India have successfully established a dominant digital
presence in the absence of adequate external deterrents. While the exact factors enabling this dominance
require further exploration, as we dig deeper in the forthcoming sections, it is likely driven by aggressive
digital marketing strategies, seamless payment processing, and an unrestricted user experience.

Although this report does not focus on the product offerings that may be enticing unsuspecting users to
these platforms, features such as real-time betting options, high-frequency wagering opportunities, live in-
game betting, instant cashouts, and personalized betting recommendations create a highly immersive and
engaging environment. This may contribute to a dynamic and addictive experience, encouraging prolonged
user activity.

Furthermore, the absence of responsible gambling measures—such as self-exclusion tools and user
defined deposit limits—allows users to bet indefinitely, increasing the risk of financial harm and gambling
addiction. Additionally, the lack of regulatory barriers, such as Know Your Customer (‘KYC’) verification,
makes these platforms even more appealing to users seeking quick, unrestricted access to betting services.
This seamless and frictionless experience, coupled with minimal oversight, enables illegal operators to
sustain high user retention and engagement.

23
“Reducing online gambling black markets - an analysis of international practices used to combat online gambling black markets,” Regulus Partners,
September 2024, https://www.entaingroup.com/media/zh2n0i0s/regulus-report-2024-black-market-gambling.pdf.
PAGE 13
III. ILLEGAL MARKETS IN INDIA - WHO ARE THE ENABLERS?

In the light of the above discussion, a critical question arises: How do illegal betting and gambling
operators attract substantial traffic to their platforms despite existing regulatory restrictions?

A 2018 report to the European Commission highlighted that the primary challenge in regulating online
illegal services stems from the intricate ecosystem of service providers that support them.24 This
ecosystem—shaped by rapid advancements in internet technologies and digital business models—
encompasses cloud computing, affiliate marketing, targeted advertising, social media, and diverse
payment services.

In the Indian ecosystem, a systematic review of government documents analysing the modus operandi of
these platforms reveals that illegal gambling and betting platforms exhibit a striking consistency in their
core operational strategies, employing well-defined methods for user acquisition, engagement, and
financial transactions. Find the review of government documents attached in Annexure I.

At the heart of their operations lies the fundamental objective of attracting and retaining users, a goal
primarily achieved through extensive, aggressive and often exaggerated advertising campaigns. Both digital
and outdoor advertisements play a significant role in promoting these platforms, with digital advertising
serving as a preferred medium for reaching potential users through targeted promotions, influencer
endorsements and paid advertisements.

Once user interest is generated, these platforms utilise alternative access channels, including APK
downloads and mirror site links, shared through communication networks like Telegram, WhatsApp, and
Discord to facilitate access. Beyond user acquisition, the long-term sustainability of illegal operations also
hinges on a sophisticated payment infrastructure, which ensures seamless deposit and withdrawal
processes while evading financial oversight.

To evaluate these dynamics, the following section delves into two critical aspects: digital advertising
strategies employed for user acquisition and payment mechanisms that facilitate seamless financial
transactions. By applying empirical methodologies to both domains, we aim to derive objective, data-
driven insights. This study marks a first of its kind effort in India, shedding light on the underlying digital
ecosystem that sustains illegal betting and gambling markets.

Globally, regulators have leveraged similar empirical approaches to examine illicit markets, assess
vulnerabilities, and refine enforcement strategies for more effective regulatory interventions.25

24
“Evaluation of Regulatory Tools for Enforcing Online Gambling Rules and Channelling Demand towards Controlled Offers,” European Commission, November
2018, https://op.europa.eu/en/publication-detail/-/publication/6bac835f-2442-11e9-8d04-01aa75ed71a1/language-en.
25
“Unlicensed gambling – Using data to identify unlicensed operators and estimate the scale of this market - October 2024,” Gambling Commission, UK,
October 21, 2024, https://www.gamblingcommission.gov.uk/statistics-and-research/publication/unlicensed-gambling-using-data-to-identify-unlicensed-
operators-and-estimate; “Evaluation of Regulatory Tools for Enforcing Online Gambling Rules and Channelling Demand towards Controlled Offers,” European
Commission, November 2018, https://op.europa.eu/en/publication-detail/-/publication/6bac835f-2442-11e9-8d04-01aa75ed71a1/language-en.
PAGE 14
DIGITAL ADVERTISING
As digital consumption rises, so does the appeal of online advertising—this holds true across industries,
including the illegal gambling and betting market. Marketing is a cornerstone of operations for illegal
gambling and betting businesses, playing a pivotal role for maximising user reach and engagement via
targeted promotions, influencer endorsements, and paid advertisements across various avenues.
Estimates reveal that illegal operators allocate between 20% and 50% of their revenue to marketing,
making it one of their most significant expenses.26

3.1 DIGITAL MARKETING IS A DIFFERENTIATOR

Digital advertising differs significantly from traditional formats like print, billboards, and broadcast media.27
It is fundamentally different in its targeted and interactive nature.

First, it leverages user data—including browsing history, metadata from accessed content, search terms,
clicked links, and location—to deliver highly personalised ads. Second, real-time bidding makes digital
advertising dynamic, allowing ad placements to be continuously optimised based on user engagement. A
third key distinction is the global reach of digital advertising intermediaries, many of which operate from
foreign jurisdictions, enforcing their own policies that may not align with national regulations. This cross-
border complexity creates conflicts of law and regulatory challenges.

It is also important to note that traditional advertising in media such as broadcast, print, and billboards is
subject to tighter regulations. However, this is not the case for the online advertising ecosystem. This is not
only due to the lack of a comprehensive regulatory framework but also because of the inherent
complexities of governing digital advertising. Enforcement remains challenging, primarily due to the
difficulty in assigning liability, which stems from the following factors:

- Operation in a ‘dark’ space, meaning the mechanisms behind ad personalisation and targeting
remain largely opaque to the public. The systems that drive these processes are neither fully
accessible nor transparently explained.

- Advertising is not always clearly distinguishable from user-generated content. The commercial
relationships are frequently opaque.

In light of the above, the current section presents an empirical analysis of the key digital marketing
channels driving traffic to four illegal gambling and betting platforms in India. The primary objective is to
identify the dominant channels driving user engagement, and examine how these channels facilitate access
to illegal websites. This analysis plays a crucial role in establishing proportional accountability within the
digital marketing ecosystem by enabling a data-driven approach to regulatory intervention.

3.2 TRAFFIC SOURCES TO ILLEGAL OPERATORS

For this analysis, we employed the same methodology outlined in the earlier section in ‘Scale and Volume’
under the Overview of Illegal Betting and Gambling Markets in India. It is important to note that online

26
“Reducing online gambling black markets - an analysis of international practices used to combat online gambling black markets,” Regulus Partners,
September 2024, https://www.entaingroup.com/media/zh2n0i0s/regulus-report-2024-black-market-gambling.pdf.
27
“Evaluation of Regulatory Tools for Enforcing Online Gambling Rules and Channelling Demand towards Controlled Offers,” European Commission, November
2018, https://op.europa.eu/en/publication-detail/-/publication/6bac835f-2442-11e9-8d04-01aa75ed71a1/language-en.
PAGE 15
advertising takes various forms.28 In this study, we focused on four key traffic sources: Social Media, Search
(both Organic and Paid), Referral, and Direct Visits.

a. SOCIAL MEDIA

Social media advertising falls into two categories: Advertising offered and placed by the social media
companies itself, and advertising placed by users in their posts and presented as user-generated content.
In user-generated marketing, individuals (who may be influencers) leverage their personal networks to
distribute promotional content, blurring the distinction between organic user content and paid advertising.

However, the current dataset does not distinguish between paid and organic social traffic. As a result, both
sponsored content and user-generated content on social media are grouped under the ‘social media’
category. This includes traffic from platforms such as YouTube, Instagram, WhatsApp Web, Twitter/X,
Facebook, Reddit, and others.

Key findings:

● Social media drove ~ 42.8 million visits to

the four analysed illegal operators in 3
months.
● This traffic stems from direct paid
advertisements such as from Facebook Ad
Network, promoted content, influencer
marketing and social media engagement
campaigns.
● The majority of traffic is coming from
mobile devices, highlighting the importance
of mobile-first advertising strategies
Figure 2: Traffic driven by social media. adopted by illegal operators.

b. SEARCH

Search is categorised into two main types: Organic and Paid. Organic search refers to the process of finding
information on the internet by entering a query into a search engine like Google or Bing. It relies on a
search engine’s algorithms to discover, rank, and display web pages based on factors such as content

28
“Evaluation of Regulatory Tools for Enforcing Online Gambling Rules and Channelling Demand towards Controlled Offers,” European Commission, November
2018, https://op.europa.eu/en/publication-detail/-/publication/6bac835f-2442-11e9-8d04-01aa75ed71a1/language-en.

As per European Commission report, “Evaluation of Regulatory Tools for Enforcing Online Gambling Rules and Channelling Demand towards Controlled Offers,”
these can be classified as: (a) Digital Display Marketing – includes banner ads and pop-ups, typically placed through ad exchanges or networks; (b) Search Engine
Marketing – comprises keyword-based advertising and organic search optimisation strategies; (c) Social Media Advertising – paid advertisements directly placed
by social media platforms, such as banners, pop-ups, sponsored posts, commercial tweets, and pre-roll video ads on video-sharing sites, often facilitated through
ad exchanges or networks; For this study, the social media traffic data captures visits originating from social media platforms such as Facebook & Instagram; (d)
Affiliate, Influencer, and Brand Ambassador Marketing – promotional content created by third parties endorsing products or services in diverse formats; (e)
User-Generated Advertising on Social Media – organic content such as posts, tweets, and video promotions that serve as indirect advertising; and (f) Advertising
through websites such as gambling tipsters, comparison sites, information sites (advertorials).

Note: These categories frequently overlap or blur in practice.

PAGE 16
relevance to the user’s query; page quality and structure; and authority, based on backlinks from reputable
sites. Websites improve their visibility in organic search through search engine optimisation (‘SEO’), a
process that enhances a page’s ranking based on the above factors.

On the other hand, paid search is where businesses pay to display ads on search engine results pages
(‘SERPs’). The most common model is pay-per-click (‘PPC’), where advertisers bid on keywords relevant to
their business and pay a fee each time a user clicks their ad. The placement of paid ads in search results
depends on bid amount (how much the advertiser is willing to pay per click); ad relevance to the search
query; and ad quality, as determined by search engine algorithms. Paid search ads typically appear in the
sponsored results section of SERPs, above organic search results (See Annexure II).

Key findings: Organic

● Organic traffic drove approx 184 million

visits to four analysed illegal platforms in 3
months.
● Illegal operators likely use aggressive SEO
tactics to rank highly for searches like “best
IPL betting site” and “online casino without
KYC,” maximising visibility and user
attraction.
● Indexed resources and links keep these
websites easily accessible,, even to
Figure 3: Traffic driven by organic search. unsuspecting users who may stumble upon
them unintentionally while searching for
related content.
● Search engines likely do not flag harmful
websites, offer safe browsing, or reduce
illegal operators’ visibility through blur
options.

Key findings: Paid

● Paid traffic data was available only for Stake, which recorded 21.6 million visits driven by paid
advertising—primarily through mobile ads.
● Businesses pay to search engine providers for displaying these ads, therefore the extent of control
exercised by search engine providers over these advertisements is likely absolute.
● Due to the lack of mobile paid traffic data for other operators, drawing broader conclusions is
challenging. However, given Stake’s significant traffic stemming from paid advertising on mobile, it
is reasonable to infer that other operators are also allocating substantial budgets toward paid
search advertising.

c. REFERRAL

PAGE 17
Referral traffic refers to visits that originate from external sources such as affiliates, content partners,
media coverage, and direct link placements on third-party websites, not via search engine or direct links.
This includes traffic generated through blogs, affiliate marketing networks, and direct media buying.
Key findings:

● Referral traffic drove approximately 247.5

million visits to four analysed illegal
platforms.
● The chart below shows referral traffic
sources: Major sources are Adult sites;
Sports-related websites; Streaming
services; and Others including file-sharing,
hosting and media platforms.

Figure 4: Traffic driven by referrals.

Figure 5: Describes the categories of websites that are driving referral traffic to illegal operators.

d. DIRECT VISITS

Traffic from users directly entering the URL, using a bookmark, or clicking a saved link. Direct traffic occurs
when users enter the website URL directly into their browser, indicating strong brand awareness. This
could also be a link outside the web browser (like a messaging app).

PAGE 18
 Key findings:

● Direct traffic accounted for 1.098 billion

visits to the four analysed illegal platforms.
● This surge may be driven by previous
marketing campaigns, word-of-mouth
referrals, or a loyal user base that has
bookmarked these sites, bypassing search
engines and ads altogether.
Figure 6: Traffic driven by direct visits.

e. COMMUNICATION PLATFORMS

Beyond these above-discussed digital advertising channels, communication channels warrant separate
consideration. It is important to note that traffic data was not analysed for these platforms, and certain
communication channels, such as WhatsApp Web, have been covered under the ‘social media’ category.

We have found evidence that communication platforms like WhatsApp & Telegram are extensively used by
illegal operators to promote their businesses. In particular, influencers with millions of followers leverage
these platforms’ broadcast features—known as “Channels”—to disseminate gambling and betting
advertisements. These channels function similarly to influencer pages on social media, allowing content to
reach large audiences instantly.

On WhatsApp Channels, while some features resemble standard chats, they operate as one-way
broadcasts rather than interactive conversations. Followers cannot reply directly or message channel
admins but can engage with content through emoji reactions and poll votes, increasing its visibility.

A comprehensive overview of the entire ecosystem is presented in the table below.

Marketing Mechanisms Supply Chain Host

Channel

Social Direct Purchased directly from social Instagram, Facebook, Twitter/X,

Media media providers LinkedIn, Snapchat, Youtube.

Brand Pages Hosted by brands/advertisers on Instagram, Facebook, Twitter/X,

social media LinkedIn, Snapchat, Youtube.

Fan and Community User-generated profiles or groups Instagram, Facebook, Twitter/X,

Pages created by third parties to promote LinkedIn, Snapchat, Youtube.
or discuss topics/brands

Influencer Marketing Hosted by influencers to create Instagram, Facebook, Twitter/X,

posts/videos/stories showcasing a LinkedIn, Snapchat, Youtube,
product. It can be paid by brands or Telegram, WhatsApp.
unpaid organic content.

Search Organic Listing Content boosted via SEO Google, Bing, etc.
Consolidated listings

PAGE 19
 Paid Purchased directly from search Google, Bing, etc.
providers

Referral Backlinks, UTM-tagged Involves collaborations, affiliate Adult sites, Sports-related

links, and partnerships programs, PR efforts, etc. websites; Streaming services; and
Others including file-sharing,
hosting and media platforms.

Direct URL, bookmark, saved N.A. N.A.

links, word of mouth,
peer to peer sharing of
links, etc.

Communic Direct Purchased directly from Telegram, Whatsapp, Discord, etc.

ations communication platforms.
Platforms
Influencer Marketing Hosted by influencers to create Telegram, Whatsapp, Discord, etc.
posts, videos, or stories showcasing
the product.

3.3 DIGITAL PLATFORM POLICIES

The platform advertising policies of major digital platforms primarily regulate paid advertisements placed
through the platform itself and the community guidelines apply to user-generated content promoting
illegal content including gambling/betting. Below is a summary of the gambling advertisement policies and
content guidelines of major platforms.

Policies Relating to Gambling and Betting Content

Platform For Advertisers For Users
Meta’s Online Gambling and Games Advertising Meta’s Community Standards:30
Policy:29 - Outline what is and isn't allowed on Facebook,
- Requires advertisers to obtain written Instagram, Messenger and Threads.
permission before running ads promoting online - If content violates these standards, Meta may
gambling or gaming. take enforcement action.
- To do so, advertisers must submit a request - One relevant subcategory, “Restricted goods and
through Meta’s designated form and provide services,” states that content attempting to sell,
Meta evidence that the gambling activities are trade, depict, or promote online gambling
appropriately licensed by a regulator or services—where monetary value is required to
otherwise established as lawful in territories participate or forms part of the prize—is
they want to target. restricted to users aged 18 and above.
- Additionally, Meta prohibits targeting users - Meta’s Community Standards also apply to
under 18 for online gambling and gaming ads. pages, groups and events, and the policy
stipulates that it should be ensured that the
content created, or permitted to be created,

29
“Online Gambling and Games,” Advertising Standards, Policies, Meta, https://transparency.meta.com/en-gb/policies/ad-standards/content-specific-
restrictions/gambling/.
30
“Restricted goods and services,” Community Standards, Meta, https://transparency.meta.com/en-gb/policies/community-standards/regulated-goods/.
PAGE 20
 complies with these standards.31
WhatsApp Business Messaging Policy stipulates:32 Under Channel Guidelines, WhatsApp states that action
- Businesses must obtain prior written approval may be taken against channels that violate its policies.33
from Meta, via an application form, to promote These guidelines include:
online gaming through WhatsApp Business. - A prohibition on sharing illegal content or
- Additionally, they must provide evidence that engaging in illegal activity, explicitly banning
their online gaming services are properly CSAM content and any material that depicts,
licensed by a regulatory authority or otherwise threatens, or promotes sexual violence, assault,
established as lawful. or exploitation.
- Furthermore, businesses must comply with - A requirement to keep content age-appropriate
additional legal and technical obligations, for all WhatsApp users, meaning channels must
WhatsApp including holding all necessary licenses, permits, not feature excessively violent, graphic imagery
notices, and registrations. or sexually explicit content, as restricted by app
- The policy also stipulates that messaging must store policies.
not be directed at individuals under the age of
18. Note: While gambling is not explicitly mentioned, since
- Moreover, if a country or region prohibits the government considers advertisements for prohibited
certain activities—such as gambling, games of content illegal, it may still fall under WhatsApp’s broader
chance, or other related services (e.g., in mandate against sharing illegal content.
India)—business messaging must exclude such
prohibited activities and only promote those
that are legally permitted.
Google Ad policy states:34
- Gambling-related ads are allowed if they comply
with its policies and the advertiser has received
the proper Google Ads certification.
- Gambling ads must target approved countries,
have a landing page that displays information
about responsible gambling, and never target
minors.
- For an entity to advertise for online gambling, it
Google must be certified by Google.
- Additionally, Google imposes country-specific
restrictions on gambling advertisements. If a
country is not listed among the approved
regions, Google Ads does not support gambling
advertising in that location.
- For India, Google explicitly prohibits gambling-
related ads for location-based (“brick-and-
mortar”) gambling and does not allow the
promotion of online casino games.

31
“Pages, groups and events,” Terms of Service, Meta, https://www.facebook.com/policies_center/pages_groups_events.
32
“WhatsApp Business Messaging Policy,” WhatsApp, https://business.whatsapp.com/policy.
33
“WhatsApp Channels Guidelines,” WhatsApp, https://www.whatsapp.com/legal/channels-guidelines.
34
“Gambling and games,” List of ad policies,
Google,https://support.google.com/adspolicy/answer/6018017?hl=en&ref_topic=1626336&sjid=1591255722624636139-NC#zippy=%2Csee-country-
requirements%2Cindia.
PAGE 21
3.4 GAPS IN ENFORCEMENT: INTERMEDIARIES AND GAMBLING ADVERTISEMENT POLICIES

Our analysis of digital platform policies reveals that while strict regulations exist for paid advertisements,
enforcement remains inconsistent. At the time of writing this report,35 Meta was hosting 1040 ads across
all its platforms, including Facebook, Instagram, Messenger, and Threads, across various media formats
under just the keywords “gambling” and “betting” on its feed36 (Attached in Annexure III). Moreover, the
number of such ads has steadily risen between 2022 and 2023, with an exponential surge in 2024.37

It is important to note that if additional keywords are searched, or if different permutations and
combinations of keywords are used, the total number of live ads running across Meta platforms would be
significantly higher.

This is in contravention of its policies and Rule 3(1)(b) of the amended Information Technology
(Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (‘IT Rules’), which mandates that
intermediaries: “intermediary shall… make reasonable efforts by itself, and to cause the users of its
computer resource to not host, display, upload, modify, publish, transmit, store, update or share any
information that,

(ii) … relating or encouraging money laundering or gambling,”

In addition to the IT Rules, the Guidelines for Prevention of Misleading Advertisements and Endorsements
for Misleading Advertisements, 2022 impose further restrictions. These guidelines prohibit advertisements
for products and services that are banned by law, ensuring that all promotional content, regardless of the
medium, must comply with existing legal frameworks.

3.5 CHALLENGES IN REGULATING USER-GENERATED CONTENT

35
As of February, 2025.
36
These results are solely for the keywords “gambling” and “betting”.
37
The data is for June- December for each year. Source: Meta Ad Library.
PAGE 22
Enforcement gaps become even more evident in the case of user-generated content. The distinction
between commercially-driven user-generated promotions and organic content is often unclear, leading
platforms to adopt a hands-off approach. This allows influencers and affiliates to promote illegal gambling
and betting under the guise of personal expression. As a result, user-generated gambling advertisements
largely escape regulation, despite Rule 3(1)(b) explicitly requiring intermediaries to take reasonable steps
to prevent the hosting and display of gambling-related content. The intermediaries adopt a hands-off
approach and defend their position by citing the vast scale of the internet, arguing that while they have
content moderation policies in place, it is not feasible to monitor every piece of content in real-time.

Internationally, however, regulators actively collaborate with these platforms to monitor content and have
informal mechanisms in place to identify and flag illegal gambling and betting material, including user-
generated content.38

3.6 GOVERNMENT ACTION

These activities have not gone unnoticed and have garnered significant government attention. In response
to the growing prevalence of advertisements promoting illegal gambling and betting, the Ministry of
Information and Broadcasting (‘MIB’), along with the Ministry of Consumer Affairs and the Central
Consumer Protection Authority (‘CCPA’), has issued multiple advisories. A list of relevant advisories issued
by the MIB and CCPA has been included in Annexure IV.

These advisories have been directed at a broad spectrum of entities within the advertising ecosystem,
including manufacturers, advertisers, publishers, intermediaries, social media platforms, celebrities,
influencers, endorsers, and other relevant stakeholders. The advisories emphasise that betting and
gambling are illegal activities, making the advertisement or promotion of such platforms—whether directly
or indirectly—on any media platform a violation of various applicable laws.

While these advisories represent a positive step forward and have been somewhat effective in addressing
the issue on television and print media, their impact in the digital space remains limited. As discussed
above, the dynamic and decentralised nature of digital platforms, combined with the complexity of the
digital marketing ecosystem, poses significant enforcement challenges. Digital advertising involves multiple
intermediaries, including advertisers, ad exchanges, publishers, and influencers, often blurring the
distinction between advertisements and organic content. In addition to this, the state enforcement has
largely remained vague.

3.7 CONCLUSION

Digital platforms, including social media, search engines, and communication channels, are driving
significant traffic to illegal betting and gambling operators. Despite existing platform policies, enforcement
remains ineffective, and government actions have been largely limited to advisories without tangible
sanctions. While challenges persist in regulating digital advertising, the fact that a significant portion of
social media and online advertising is controlled by a handful of conglomerates presents an opportunity for
more effective regulatory engagement and enforcement measures.

38
- Please see the International Comparison Section for a detailed discussion
PAGE 23
PAYMENT ECOSYSTEM
In India, where digital payments are undergoing a rapid transformation, illegal gambling and betting
platforms are increasingly exploiting the payment ecosystem to facilitate their operations and evade
regulatory scrutiny. By leveraging varied financial channels and constructing complex transaction routes,
these entities obscure the flow of funds, making it difficult for authorities to track and intercept illicit
transactions. This exploitation extends beyond merely processing payments (for deposits and
withdrawal)—it also serves as a vehicle for large-scale money laundering.39

In this context, the Department of Revenue, in its submission to the Parliamentary Standing Committee on
Finance, highlighted alarming patterns of suspicious financial activity linked to such illegal platforms:40

“Prima facie, it appears that these websites are registered overseas in Curacao, Malta, Cyprus etc.
Though the websites itself were registered in foreign countries, but all of them were linked to Indian
Bank Accounts. During analysis of the financial transactions linked to the UPI ids, it was found that the
network of foreign registered websites linked to Indian bank accounts appear to be engaged in
fraudulent means of collecting money from individuals through false inducements. The collected funds
were not distributed back to those who invested or played and were instead diverted to bank accounts
of a few individuals and entities including those based abroad, and by investing the said funds for
purchase of crypto currency.”

Multiple government assessments also observed that UPI and others channels enable illegal gambling and
betting operators to provide seamless deposit channels; facilitate bulk payouts to users;41 and layer
transactions, effectively laundering money by obfuscating its origin.42 Notably, UPI is primarily being
exploited through mule networks, while certain payment channels actively facilitate the movement of
these funds. Shell companies are also involved in providing a cover for disguising the origin of funds and
adding a layer of legitimacy to the financial transactions of illegal operators, helping to mask the true
purpose of their transactions.

FATF India Mutual Evaluation Report:43 Tracing Illegal Gambling Funds Through Shell Companies and
Payment Gateways

The Zonal Offices received information about gambling and betting sites being promoted on social
media. To track the money flow, the Enforcement Directorate (‘ED’) created an online ID and made a
small deposit using a link from the site. Investigators joined online discussions and found that people
were being tricked into investing money in gambling schemes across India.

The collected funds were processed through a payment gateway and transferred to a company
account. Further investigation revealed that this company was a shell company with minimal capital

39
“Explained: How ED busted the Rs 400 crore Fiewin gaming app scam,” Business Standard, September 25, 2024, https://www.business-
standard.com/finance/personal-finance/explained-how-ed-busted-rs-400-crore-gaming-app-scam-124092500433_1.html.
40
“Cyber Security and Rising Incidence of Cyber/White Collar Crimes,” Fifty Ninth Report, Standing Committee on Finance (2022-2023), July 27, 2023,
https://sansad.in/getFile/lsscommittee/Finance/17_Finance_59.pdf?source=loksabhadocs.
41
Press release, Enforcement Directorate, August 16, 2024, https://enforcementdirectorate.gov.in/sites/default/files/latestnews/PRESS%20RELEASE%20-
Fiewin%20Arrest%20-15-08-2024.pdf.
42
“Delhi-Based NBFC Exposed As Key Player In Fairplay Betting App's ₹4,500 Crore Money Laundering Scheme,” The Free Press Journal, December 19, 2024,
https://www.freepressjournal.in/mumbai/delhi-based-nbfc-exposed-as-key-player-in-fairplay-betting-apps-4500-crore-money-laundering-scheme.
43
“Mutual Evaluation Report - India,” FATF, September 2024, https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/India-MER-
2024.pdf.coredownload.inline.pdf.
PAGE 24
 and no real business operations. It was part of a network of 56 companies with shared directors and
shareholders, all controlled by a foreign national.

By analysing transaction patterns, investigators found that money was deposited in small amounts
across multiple bank accounts and later consolidated into a few key accounts. Through undercover
operations and controlled tracking, authorities conducted searches and seized important documents.
ED also obtained bank records to support the investigation.

3.8 MAKING PAYMENTS ON ILLEGAL OPERATORS

To analyse payment options on five illegal betting and gambling platforms, we conducted a primary review
of their supported methods:

OPERATOR ACCEPTED PAYMENT METHOD

Stake UPI, Net Banking, Cryptocurrencies (Litecoin, USD Tether, Solana, Ethereum, Bitcoin)
Parimatch UPI (PayTm, Google Pay, PhonePe, etc.), Net Banking, Debit / Credit Card, AstroPay, Cash on delivery
UPI (PhonePe, Google Pay, PayTm), Net Banking (IMPS, NEFT), Payment Gateways, Debit / Credit Cards, E-
Fairplay Wallets (Trustly, PayPal, Neteller, AstroPay), Cryptocurrencies (Bitcoin, Ethereum)
UPI (PhonePe, Google Pay, PayTM UPI), Cryptocurrencies (Tron, Bitcoin, Ethereum, Solana, etc.), Cash, Bank
1xBet Transfer (IMPS, NEFT), and E-Wallets (Skrill, AstroPay)
Dafabet UPI, Local Bank Transfer, E-Wallet (Payz, Skrill, AstroPay), Cryptocurrencies (GDPay, DirePay, OpenNode)

INSIGHTS INTO THE PAYMENT PROCESS ON PARIMATCH

While attempting to deposit funds on pari-match-in.com, we initially found three payment options: QR Pay (UPI),
PayTM, and Astropay.

● The deposit option redirected us to a “PaytoUPI” page, where selecting “UPI” revealed multiple options,
including BHIM, GPay, PhonePe, PayTM, PayZapp, and scan-to-pay.
● First Attempt: Using Payment Option 1, we were redirected to a payment page, which triggered a security
warning. The recipient, “Kartami Fintech Private Limited,” was flagged as a potential risk, advising us to
reconsider or cancel. Even after dismissing the warning, a persistent message urged caution and provided
an option to block the recipient. Despite this, we proceeded with the payment and it went through
successfully.
● Second Attempt: When we re-attempted a second deposit via Payment Option 1, the recipient account
had changed, indicating the use of multiple mule accounts. This time, no security warnings appeared.
● Alternative Platform: Using Payment Option 2, no security alerts were triggered.
● Post-Deposit Changes: After the first deposit, additional payment methods, including cryptocurrency,
became available. Further, the minimum deposit threshold increased from INR 500 to INR 2,000 on the
second attempt.

The warnings highlight varying fraud detection capabilities among UPI providers. In a 2022 blog post, GPay
detailed its approach:44

44
“Google for India 2022: Using AI to make Google more helpful, secure, and private for India's changing digital needs,” Google - India Blog, December 19, 2022,
https://blog.google/intl/en-in/company-news/inside-google/google-for-india-2022-product-announcements/.
PAGE 25
 “we use advanced methods in our safety engine that analyze aggregate transaction patterns of
millions of users, relating this to a graph of a billion nodes. This system helps identify possible flags on
fraudulent behaviour, then uses its intelligent language engine to flash a warning and notify the user in
their most preferred language. In some cases, we also generate a quick vibration to really get your
attention!”

The discussion underscores the pressing need for a thorough evaluation of how payment channels are
being exploited and the vulnerabilities that persist within India’s financial ecosystem. Such an assessment
will be instrumental in identifying mitigation measures.

3.9 REGULATORY SCRUTINY

Recognising the growing misuse of payment systems by illegal operators, Indian authorities have
intensified regulatory scrutiny. In October 2024, the Indian Cybercrime Coordination Centre (‘I4C’), under
the Ministry of Home Affairs, issued an advisory warning against illegal payment gateways.45 The advisory
detailed how transnational organised cybercriminals create unauthorised payment gateways using mule
bank accounts for accepting deposits on illegal platforms like fake investment scam sites, offshore betting
and gambling websites, fake stock trading platforms, etc. Among the identified illegal payment gateways
were PeacePay, RTX Pay, PoccoPay, and RPPay—platforms allegedly operated by foreign nationals
providing “money laundering as a service”.

In addition to this, in October 2023, The Economic Times reported that the central government was
considering stricter UPI regulations to curb offshore gambling platforms.46 However, it remains unclear
why these measures were not pursued or implemented. Further, the Law Commission’s observations
regarding payment-related obligations to curb illegal gambling operations are particularly significant.47 The
report highlights:

“5.16 Under section 17 of the Act, 2007, the Reserve Bank of India has been given the right to draft
policies, in accordance with this Act, on demand for almost everything involving payment processing in
India, which are to be compulsorily complied with as provided in section 19 of the Act.

5.17 In the past, RBI has exercised the powers under this Act to achieve its objective, by going after
PayPal India, Neteller and Entro Pay. If the RBI were to similarly decide to go after gambling processors,
the legal framework and authority, as it already exists, would, in fact, make it possible to curb the
functioning of these gambling processors.”

Therefore, if the RBI were to extend similar enforcement measures to gambling payment processors, the
existing legal framework provides sufficient authority to effectively disrupt and restrict their operations.

45
Press Release, Ministry of Home Affairs, October 28, 2024, https://pib.gov.in/PressReleaseIframePage.aspx?PRID=2069000.
46
“Centre planning to raise odds against illegal betting companies,” The Economic Times, October 16, 2023,
https://economictimes.indiatimes.com/tech/technology/centre-planning-to-raise-odds-against-illegal-betting-
companies/articleshow/104448674.cms?from=mdr.
47
“Legal Framework: Gambling and Sports Betting Including in Cricket in India,” Report No. 276, Law Commission of India, July 2018,
https://cdnbbsr.s3waas.gov.in/s3ca0daec69b5adc880fb464895726dbdf/uploads/2022/08/2022081655-1.pdf.
PAGE 26
IV. ENFORCEMENT MEASURES AROUND THE WORLD

Across the world, a variety of tools have been tested and put into implementation to control illegal
gambling and betting. Among these, website blocking is the most common enforcement tool. According to
a report by the European Commission on the regulation of illegal online betting and gambling, 60% of
EU/EEA member states have used website blocking in the past.

4.1 WEBSITE BLOCKING IS THE MOST COMMON ENFORCEMENT MECHANISM

Website blocking refers to a practice where internet users trying to access unauthorised websites are
prevented from accessing. Users are often redirected to landing pages informing them of the illegal nature
of the offer. Illegal betting and gambling is typically available through operators licensed in tax havens and
low-regulation jurisdictions, but not in the country of consumption. The three most common measures
employed by countries of consumption to block such operators are: Internet Protocol (‘IP’) address
blocking, Domain Name System (‘DNS’) blocking, and Uniform Resource Locators (‘URL’) blocking.48

4.2 EFFECTIVENESS OF BLOCKING

The effectiveness of blocking can be measured in terms of either preventing or at least decreasing the
consumption of illegal betting and gambling. Experiences of effectiveness appear to vary across countries
that have adopted blocking. An analysis of cases in the early 2000s, in the United States, the United
Kingdom, and Australia found that while blocking can create initial barriers, it fails to completely prevent
access to illegal gambling sites. This is primarily due to several circumvention tactics employed by both
users and operators. More recent case studies from Denmark, Germany, and France indicate that multiple
factors influence the overall effectiveness of blocking measures, including:

a. Use of VPNs by customers to mask their location and bypass geo-restrictions.

b. URL switching by operators, where websites quickly rebrand (e.g., betnow.com becomes
betnow222.com) to evade blocks. The flexibility of illegal operators enables them to swiftly change
IP addresses, making their platforms accessible again.
c. Direct communication via phone calls or messaging apps, allowing operators to guide users to
alternative platforms or provide direct links to access blocked services.

Another issue relates to the adequate resourcing of regulators as well as their willingness and capability to
employ blocking measures.

4.3. TAKING AN ECOSYSTEM APPROACH TO TACKLING ILLEGAL BETTING AND GAMBLING

Countries have increasingly recognised that blocking alone is not an effective tool for combating illegal
betting and gambling. As highlighted by the European Union, UNODC and multiple regulators, the presence
of multiple service providers supporting this ecosystem necessitates a comprehensive, ecosystem-based
approach to enforcement. Academic research on the subject also suggests that a combination of
48
IP address blocking: IP blocking is effective but carries the risk of ‘over blocking’. Many websites are hosted under one IP address including also legitimate
(i.e., non-blocked) addresses. This renders this method less functional in achieving the goal of preventing illegal betting & gambling. DNS blocking: DNS blocking
is the cheapest and easiest,therefore widely used across the world. URL blocking: URL blocking is precise but requires deep-packet-inspection (‘DPI’). The DPI
technique enables Internet Service Providers (‘ISPs’) to monitor communication. DPI though is costly and difficult to use for encrypted connections.
PAGE 27
restrictions on marketing, payments and ISP blocking—proves to be significantly more effective.49 In light
of these findings, we have compiled an analysis of enforcement strategies adopted by different countries
to address the challenges posed by illegal operators.

a. Preventing Marketing & Enforcement through Intermediaries

Restricting illegal advertising is key to the regulation of illegal markets and a major aspect of ensuring the
effectiveness of enforcement. Countries in the European Union, Australia, and the United Kingdom have
significantly improved enforcement against illegal gambling advertisements on social media by actively
collaborating with major digital platforms.

A comparative study conducted by the EU in 2018 found that 19 out of 24 national regulators had
established some form of cooperation with social media companies.50 Regulators engaged with platforms
such as Facebook, Twitter, YouTube, and Google, working to remove illegal gambling advertisements or
downgrade the ranking of illegal gambling sites in search results. Several other countries, including Spain,
the UK, France, and Norway, have collaborated with Google and other smaller search engines to limit the
visibility of illegal betting and gambling promotions.51

Successful Case Studies of Effective Cooperation

a. Norway: Norwegian Gaming Authority worked with online newspapers to ensure the removal of
illegal gambling ads, even when purchased through ad exchanges. This approach effectively
reduced illegal gambling advertisements on Norwegian news sites.
- The authority also had a good dialogue with Facebook whereby it informed Facebook about
gambling companies having Facebook pages in Norwegian directed to Norwegian citizens.52 In
response, Facebook took the pages down.
- Additionally, the authority reported gambling brand ambassadors promoting illegal platforms via
their personal Facebook pages. Almost all of them were taken down, and the authority has now
established a direct reporting channel with Facebook for ongoing enforcement.

b. Denmark: In 2023, the Danish Gambling Authority expanded its enforcement by targeting gambling
apps hosted on digital platforms. The authority partnered with Apple, gaining special access to
report illegal gambling apps on the App Store, leading to their removal from the Danish App Store.53
- A similar collaboration with Google was established, allowing the authority to report/remove illegal
gambling apps from Google Play and flag illegal content on YouTube and Google’s search engine.
- Through its partnership with Facebook, the authority now has direct access to report illegal
gambling content and advertisements, leading to their removal from Facebook and Instagram.

c. Belgium: The Belgian regulator has an informal agreement with Google to ensure that illegal
betting and gambling websites are ranked significantly lower in search results and that sponsored
ads for unauthorised operators are blocked.

49
“Evaluation of Regulatory Tools for Enforcing Online Gambling Rules and Channelling Demand towards Controlled Offers,” European Commission, November
2018, https://op.europa.eu/en/publication-detail/-/publication/6bac835f-2442-11e9-8d04-01aa75ed71a1/language-en.
50
Id.
51
Id.
52
Id.
53
“Report on Illegal Gambling 2023,” Danish Gambling Authority, March 2024, https://www.spillemyndigheden.dk/uploads/2024-
04/Report%20on%20illegal%20gambling%202023.pdf.
PAGE 28
 - Additionally, the regulator has held regular discussions with Google regarding the presence of
illegal gambling promotions and links.

b. Payment Blocking

Payment blocking is a regulatory mechanism designed to disrupt financial transactions associated with
illegal gambling platforms. It requires banks and payment service providers in the enforcing country to
identify and block transactions linked to illegal gambling activities. The objective is to cut off financial
access, making it more difficult for users to deposit or withdraw funds, thereby discouraging participation
in illegal gambling operations.

In 2018, an EU-wide analysis found that 52% of member states had legal provisions for payment blocking,
while 30% had implemented these mechanisms.54 The enforcement of these mechanisms involved a
diverse range of payment providers tasked with blocking transactions. The most commonly targeted
entities were e-payment service providers (34%), followed by traditional card networks (31%) and internet
payment gateways (25%).55 In many cases, regulators maintain blacklists of unauthorised gambling and
betting operators, which financial institutions use to identify and block transactions.

The Czech Republic prohibits crediting and debiting transactions to accounts associated with unauthorised
gambling and betting, requiring payment providers to cease processing payments within 15 days of an
operator being blacklisted.56 Similarly, Hungary has mandated that banks block payments to blacklisted
operators since July 2023. The Hungarian Gambling Authority has also warned customers that winnings
from unlicensed platforms may not be honored. Following the enforcement of these restrictions, several
operators exited the Hungarian market. Norway has intensified its oversight by directly supervising 37
banks to ensure compliance with payment bans.

While these efforts have been somewhat effective in curbing illegal operators, enforcement measures
have faced limitations, particularly as operators continue to exploit gaps in existing frameworks. Norway’s
regulators have found that direct payments into foreign-based digital wallets remain outside the scope of
current blocking measures, leading to proposals for expanded enforcement mechanisms, including
blocking transactions based on operators’ names and imposing greater due diligence obligations on
payment service providers.57

Other countries have reported mixed results with payment blocking due to the adaptability of illegal
operators. Estonia, for instance, has faced challenges as many illegal gambling businesses have shifted
away from domestic bank accounts, to foreign financial institutions beyond the reach of national
enforcement authorities. Further, identifying and tracking financial channels used by illegal operators has
proven to be one of the most significant hurdles to effective implementation.

The United States Approach: The UIGEA Framework

The United States provides a key example of legislated payment blocking through the Unlawful Internet
Gambling Enforcement Act (‘UIGEA’). Section 5364 of the UIGEA mandates that financial transaction

54
“Evaluation of Regulatory Tools for Enforcing Online Gambling Rules and Channelling Demand towards Controlled Offers,” European Commission, November
2018, https://op.europa.eu/en/publication-detail/-/publication/6bac835f-2442-11e9-8d04-01aa75ed71a1/language-en.
55
Id.
56
Id.
57
Id.
PAGE 29
providers implement measures to identify and block restricted transactions related to online gambling.58
Rather than targeting individual users, the UIGEA focuses on financial institutions and payment processors,
requiring them to prevent transactions that fund illegal internet gambling operations. The legislation
grants the Department of the Treasury and the Federal Reserve System joint rulemaking authority to
define and enforce compliance measures.

The final rules emphasise on a “flexible, risk-based due diligence” process that payment systems may use
to gain compliance. The rules mandate “[a]ll non-exempt participants in designated payment systems shall
establish and implement written policies and procedures reasonably designed to identify and block or
otherwise prevent or prohibit restricted transactions”.

 Assessing the Effectiveness of Payment Blocking

Payment blocking has been widely adopted with research indicating that in jurisdictions like Hungary and
Norway, payment disruptions have proven highly effective in making offshore markets less attractive—
often to the point where operators are forced to withdraw.59

However, existing literature also suggests that payment blocking is most effective when combined with
other enforcement measures, particularly ISP blocking and marketing restrictions. The so-called “belt and
suspenders” approach,60 advocates for a more comprehensive strategy that targets a wider network of
financial systems, while also encouraging financial institutions to develop innovative solutions to
counteract evolving circumvention tactics. Further, others similarly argue that payment providers and ISPs
should be held accountable for implementing blocking measures effectively.61

Moreover, the effectiveness of payment blocking largely depends on how it is implemented and the
specific payment systems and financial services prevalent in a given country. Factors such as consumer
payment preferences, market structures, and local “payment culture” influence the feasibility and success
of enforcement efforts.

c. Blacklisting / Whitelisting

Some jurisdictions complement their enforcement measures by implementing blacklists and whitelists for
legitimate operators. This approach is consumer-oriented, as it not only restricts access to illegal operators
but also provides clear guidance to consumers on which platforms are licensed and regulated.

A blacklist is an official registry of operators or websites that violate laws, designating them as illegal
entities. Regulatory authorities, such as those in Australia, Belgium, and Hungary, publicly disclose these
lists to enhance enforcement transparency, while others, including the Netherlands, maintain non-public
blacklists for internal regulatory purposes. Beyond consumer protection, public blacklists serve a broader
regulatory function by acting as a mechanism for demonstrating non-compliance to other regulatory
authorities, industry suppliers, trade associations, and financial service providers. This facilitates cross-
sector collaboration, strengthens enforcement actions, and restricts access to financial and operational

58
Unlawful Internet Gambling Enforcement Act of 2006 § 802, 31 U.S.C. §§ 5364.
59
“Reducing online gambling black markets - an analysis of international practices used to combat online gambling black markets,” Regulus Partners,
September 2024, https://www.entaingroup.com/media/zh2n0i0s/regulus-report-2024-black-market-gambling.pdf.
60
Kraig P Grahmann, “Betting on Prohibition: The Federal Government’s Approach to Internet Gambling,” Northwestern Journal of Technology and Intellectual
Property (2008), 7, 162, https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=1083&context=njtip.
61
Lucy Dewar, “Regulating Internet Gambling: The Net Tightens on Inline Casinos and Bookmakers,” Aslib Proceedings (2001), 53, 9,
https://doi.org/10.1108/EUM0000000007067.
PAGE 30
resources for blacklisted entities, thereby reducing their ability to operate. Conversely, a whitelist allows
consumers to verify whether a website is licensed and compliant with regulatory standards.

PAGE 31
V. RECOMMENDATIONS

 Shifting from a Singular Blocking Approach to an Ecosystem-Based Enforcement Strategy

To effectively combat illegal online betting and gambling, enforcement measures must move beyond
isolated website blocking and adopt a comprehensive ecosystem-based approach. This strategy should
assign liability to all key enablers of the illegal market while enforcing strict compliance requirements.

 Digital Advertisements
The relevant ministries/departments such as MIB, I4C, DGGI, Department of Consumer Affairs (‘DoCA’),
Ministry of Electronics and Information Technology (‘MeitY’) should together or separately establish
collaboration/arrangements with digital advertising intermediaries, including social media platforms,
search engines, and ad networks to proactively monitor, flag, and remove illegal betting and gambling-
related advertisements. Some specific measures can be:

a. For digital platforms including social media: Enforce strict ad policies to ban direct paid
advertisements, enhance content moderation to flag/remove user-generated content relating to
illegal markets, and immediately suspend influencers promoting illegal operators.

b. Search: Downgrade search results on search engines, provide safe browsing options, and complete
ban on sponsored advertisements for illegal market operators.

In the long term, a comprehensive digital advertising policy should be developed to map the roles and
responsibilities of each stakeholder within the complex digital advertising ecosystem and assign
corresponding liabilities based on their level of involvement and control.

 Payment Ecosystem
In accordance with the Law Commission’s recommendations, the RBI, under Section 17 of the Payment and
Settlement Systems Act, may formulate guidelines or policies requiring payment systems, banks, and
financial institutions to establish mechanisms and internal policies for detecting and blocking transactions
linked to illegal betting and gambling operators. However, before implementing such a measure, it is
advisable to first conduct a comprehensive vulnerability assessment of India’s payment ecosystem.

 Improving Blocking Measures

Effective landing pages are crucial for enforcing website blocks on illegal gambling sites, therefore, we
recommend implementing clear and informative landing pages for blocked illegal betting & gambling
websites in India.

Internationally, regulators in countries such as France, Poland, Estonia and etc. have successfully adopted
this approach, where ISPs display landing pages to notify users when they attempt to access blacklisted
betting or gambling websites. These landing pages clearly inform users that the site is illegal, highlighting
the potential risks of engaging with unregulated platforms. This strategy not only raises awareness but also
serves as an effective consumer protection tool, helping to safeguard users from unsafe websites.

In India, our review of blocked URLs, including stake.com and winbuzz, highlighted execution gaps, where
landing pages either did not load or displayed generic error messages, such as "site cannot be reached."
PAGE 32
This approach fails to inform users about the website being blocked, offers no explanation for the block,
and misses a critical opportunity to educate the public on legal and safety considerations.

To address this gap, we recommend implementing structured landing pages for all blocked websites,
ensuring that users receive a clear message regarding the illegality of the site, the rationale behind the
block, and warnings about potential risks. This approach should be standardized across ISPs, with
consistent messaging and design guidelines, contributing to greater transparency and stronger regulatory
enforcement.

 Blacklist / Whitelist
To enhance enforcement measures and support the recommendations outlined above, the government
should consider establishing and maintaining regularly updated blacklists and/or whitelists of online
gaming operators. These lists should be continuously revised and, where possible, made publicly accessible
in a user-friendly format, enabling consumers to easily distinguish between legitimate and illicit operators.

For maximum impact, these enforcement efforts should be aligned with broader regulatory strategies,
including the regulation of online gaming either through operationalization of the existing Information
Technology (Intermediary Guidelines and Digital Ethics) Rules, 2021 or by introducing a dedicated
regulatory framework for the sector. By providing a clear legal framework, the government can offer
consumers better guidance, enhance consumer protection, and promote responsible gaming practices by
clearly differentiating legitimate platforms from illegal ones.

PAGE 33
 ANNEXURES
ANNEXURE I: A systematic review of government documents observing modus operandi of illegal platforms.

MINISTRY OBSERVATION

Ministry of In a press release, the MeitY clarified its intentions for bringing IT Amendment Rules 2023:
Electronics and “Betting and gambling activities are banned under various State laws, while few games of skill have been held to
Information be constitutionally valid by the Supreme Court in various judgements. In this legal landscape, the online gaming
Technology industry in India has seen immense growth in the recent past. However, despite this existing legal landscape,
various social and economic concerns have emerged from this industry over the past few years including: (c) ads of
offshore gambling and betting websites targeting Indian users;
The rules even disallow intermediaries to host or display any advertisement or surrogate advertisement or
promotion of an online game that is not a permissible online game. This will help to address the growing menace
of online ads of illegal betting and gambling operations targeting Indian users.”

Parliamentary The Parliamentary Standing Committee on Finance presented a report, “Cyber Security and Rising Incidence of
Standing Cyber/White Collar Crimes,” identifying four major trends in cybercrime:
Committee on “The first one is the use of crypto for money laundering and terror financing. The second is the use of mule
Finance accounts with false addresses. That is the second typology. The third typology is the use of international online
betting sites both for purpose of money laundering and terror financing. The fourth trend we have seen is the
lending apps and apps for investments which have been used and which have been caught in the system. So, these
four typologies have been primarily reported as regards the mule account, it is mostly in India. But in the three
other instances, the offshore entities are involved. It may be crypto. It may be the online betting sites. There is a
clear set of online betting sites which are based out of tax havens.”

Financial As per FIU’s Annual Report 2022-23, the Strategic Analysis Lab (‘SAL’) produced a typology report on Risk Analysis
Intelligence Unit of Online Gaming and Gambling in India. The report, which is not in public domain, is understood to have
highlighted the money laundering risks associated with the use of convertible and non-convertible currencies in
gaming and gambling platforms. Additionally, it examined the relevant laws and regulations, the Know Your
Customer processes followed by these platforms, and assessed the vulnerabilities and risks. The report also
identified various money laundering techniques and typologies prevalent in these industries.

The Directorate Annual report 2023-24, Trends in Tax Evasion, revealed that 658 offshore entities were identified as unregistered
General of GST and/or non-compliant, prompting investigations into their activities. In addition, 167 URLs/websites associated
Intelligence with these entities were recommended for blocking by the DGGI to curb unauthorized operations.

Enforcement In a press release, the Enforcement Directorate (‘ED’) highlighted the case of Fiewin, where the platform was
Directorate designed to collect money from users and funnel it through multiple channels before ultimately transferring the
funds to the wallets of Chinese nationals. The Fiewin app facilitated money laundering in a systematic way by
involving Indian nationals, Chinese nationals, and companies like Studio21. The ED press release detailed the
process of user acquisition, user deposits, conversion and layering of pooled funds into crypto, and eventual
transfer of those crypto assets to Chinese nations.

FATF Mutual The Mutual Evaluation Report observes that while casinos are deemed as not posing a high risk, the report does
Evaluation Report identify multiple instances where online gambling and betting platforms have facilitated money laundering. These
operations have used shell companies, cash couriers, and cryptocurrencies to channel illicit funds, reflecting
trends seen in news reports (see Pages 88, 93, 106).

Ministry of Home Indian Cybercrime Coordination Center, MHA has issued an advisory against illegal payment gateways created
Affairs using mule bank accounts by Transnational Organized Cybercriminals facilitating money laundering as a service. As
per the advisory, illegal payment gateways are created using mule accounts which are then given to criminal
syndicates for accepting deposits on illegal platforms like fake investment scam sites, offshore betting and
gambling websites, fake stock trading platforms, etc. Thereafter, funds are immediately layered to another
account as soon as the crime proceeds are received. Bulk Payout facilities provided by banks are misused for the
same.

PAGE 34
ANNEXURE II: Glimpses of sponsored ads on Google Search promoting illegal gambling and betting operators.

PAGE 35
ANNEXURE III

We also conducted a scan for live “gambling” and “betting” advertisements using Meta’s Ad Library portal.
This portal captures and provides searchable access to all ads currently running across Meta platforms,
including Facebook, Instagram, Messenger, and Threads, across various media formats.

PAGE 36
 ANNEXURE IV:

A list of relevant advisories issued by the MIB and CCPA are discussed below.

Ministry / Date Description Targeted to

Department /
Regulator

Ministry of June 13, 2022 The advisory noted that a number of advertisements of Newspapers private satellite
Information and online betting websites/platforms are appearing in print, television channels, and
Broadcasting electronic, social and online media. It noted that publishers of news and current
advertisements of online betting are misleading, and do affairs content on digital media
not appear to be in strict conformity with applicable
laws. Therefore, it advised the print and electronic
media to refrain from publishing advertisements of
online betting platforms.

Additionally, it advised the online and social media,

including the online advertisement intermediaries and
publishers, to not display such advertisements in India or
target such advertisements towards the Indian audience.

Ministry of October 3, The advisory noted that some online offshore betting Private satellite television
Information and 2022 platforms have started using news websites as a channels
Broadcasting surrogate product to advertise their betting platforms on
TV channels.

It detailed that such advertisement is prohibited in

accordance with Guidelines 2022 and the Advertising
Code under Cable TV Networks Regulation Act, 1995.

Thus, it strongly advised private satellite channels to

refrain from broadcasting advertisements of online
offshore betting platforms and/or their surrogate news
websites or any such product / service depicting these
platforms in a surrogate manner.

Ministry of October 3, The advisory noted that promotion content and Publishers of news and current
Information and 2022 advertisement of betting platforms are visible on certain affairs content on digital media,
Broadcasting news platforms and OTT platforms. and publishers of online curated
content (OTT platforms)
It further noted that some online offshore betting
platforms have started using new websites as a
surrogate product to advertise betting platforms on
digital platforms. It detailed that such advertisement is
prohibited in accordance with Guidelines 2022 and
amended IT Rules 2021.

Thus, it strongly advised online news websites and OTT

platforms to refrain from broadcasting advertisements of
online betting platforms and/or their surrogate news
websites or any such product / service depicting these
platforms in a surrogate manner.

PAGE 37
Ministry of April 6, 2023 The advisory noted that betting and gambling is an illegal Newspapers private satellite
Information and activity and hence, advertisement / promotion of such television channels, publishers of
Broadcasting activities directly or indirectly on any of the media news and current affairs on digital
platforms falls foul of various applicable statutes. media, and online advertisement
intermediaries.
It urged all stakeholders to immediately refrain from
showing any such advertisement / promotional content
in any form whatsoever.

Ministry of August 25, The advisory warned against direct and indirect Newspapers registered under
Information and 2023 advertisements of betting and gambling platforms. It Press and Registration of Books
Broadcasting noted that there is a tendency to spike promotion of Act, 1867, private satellite
such betting and gambling platforms during a major television channels, publishers of
sporting event, especially cricket. news and current affairs on digital
media, online advertisement
It advised all stakeholders to immediately refrain from intermediaries, and social media
showing such advertisements in any form whatsoever, platforms.
failing which the government may initiate appropriate.

Central Consumer March 6, 2024 The CCPA issued an Advisory on Prohibition of Entire spectrum encompassing
Protection Advertising, Promotion, and Endorsement of Unlawful manufacturers, advertisers,
Authority Activities Prohibited under Various Laws. The advisory publishers, intermediaries, social
sternly cautioned all stakeholders against featuring both media platforms, celebrities,
direct and surrogate advertisements or endorsements influencers, endorsers, and any
that promote illegal activities, particularly betting and other relevant stakeholders.
gambling.

It reiterated the legal stance on betting and gambling,

emphasising their prohibition under law. Further, the
advisory referenced Clause 9 of Guidelines 2022, which
explicitly prohibits advertisements relating to goods,
products, or services that are either explicitly prohibited
or barred from being advertised under any law.

Given that betting and gambling are prohibited by the

Public Gambling Act, 1867, and deemed illegal in most
regions of the country, any related advertisements or
promotional material are likewise prohibited.

Ministry of March 21, MIB issued its latest advisory, explicitly directing entities Endorsers and influencers, social
Information and 2024 to abstain from disseminating advertisements or media intermediaries, and online
Broadcast promotional content, including surrogate advertisement intermediaries
advertisements, related to illegal activities such as
betting or gambling.

Further, the advisory underscored the authority vested

with the MIB under Section 79(3)(b) of the Information
Technology Act, 2000, relating to ‘online
advertisements’.

As such, the MIB is empowered to issue notifications to

intermediaries, compelling them to remove or disable
access to any posts, links, or other content featuring
advertisements and branded material promoting
unlawful products and services.

PAGE 38
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