Illegal Online Betting Proceeds: Bank Accounts, Payment Wallets, Influencers and PMLA Exposure in India

Direct Answer: Illegal online betting proceeds may be traced by the Directorate of Enforcement through the complete financial and digital chain connecting the bettor, collection account, UPI ID, payment wallet, merchant account, payment gateway, panel operator, shell entity, cryptocurrency wallet, hawala intermediary, advertiser and final beneficiary.

A bank account, wallet or influencer does not become liable under the Prevention of Money Laundering Act, 2002 merely because it has some connection with a betting platform. PMLA exposure ordinarily requires an identifiable scheduled offence, property derived or obtained from criminal activity relating to that offence, and material showing that the concerned person knowingly assisted, possessed, acquired, used, concealed, transferred, projected or claimed the proceeds as untainted.

The separate Promotion and Regulation of Online Gaming Act, 2025, which was brought into force in April 2026, now directly prohibits the offering of online money-gaming services, advertisements promoting such games and facilitation of financial transactions towards those services. An advertiser, influencer, financial facilitator or platform operator may therefore face exposure under the online-gaming legislation even where the independent legal ingredients of a PMLA offence are not ultimately established.

Core distinction: A violation involving an online money game and the offence of money laundering are not automatically identical. Liability under each statute must be examined through its own statutory ingredients, evidence and procedural safeguards.

Current Legal Position on Online Money Games in India

The Promotion and Regulation of Online Gaming Act, 2025 creates a national framework that distinguishes online money games from recognised e-sports and online social games.

An “online money game” broadly covers an online game in which a user pays fees, deposits money or places another stake in expectation of monetary or other enrichment. The definition applies irrespective of whether the game is based upon skill, chance or a combination of both, while recognised e-sports are excluded from that definition.

The Act extends throughout India and also applies to online money-gaming services offered within India by operators situated outside India.

Section 5: Prohibition on Online Money-Gaming Services

Section 5 prohibits a person from offering, aiding, abetting, inducing or otherwise engaging in the offering of an online money game or online money-gaming service.

Section 6: Prohibition on Advertisements

Section 6 prohibits a person from making, causing, aiding, abetting or otherwise becoming involved in an advertisement, including an advertisement through electronic communication, which directly or indirectly promotes or induces a person to play an online money game.

This provision is particularly relevant to:

Social-media influencers;
YouTubers and streamers;
Actors, sportspersons and public personalities;
Advertising agencies;
Media-buying companies;
Affiliate marketers;
Website and application publishers;
Sports-score applications;
Telegram and WhatsApp channel operators;
Digital marketing consultants; and
Persons publishing surrogate advertisements.

Section 7: Prohibition on Transfer of Funds

Section 7 prohibits a bank, financial institution or any other person facilitating financial transactions or authorisation of funds from permitting, aiding, abetting, inducing or otherwise facilitating a payment towards an online money-gaming service.

Depending upon the facts, this provision may affect:

Banks and co-operative banks;
Payment gateways;
Payment aggregators;
Fintech companies;
UPI and wallet facilitators;
Merchant-account providers;
Collection agents;
Account providers;
Informal payment intermediaries; and
Persons knowingly supplying accounts for betting collections.

Penalties under the Promotion and Regulation of Online Gaming Act, 2025

The principal penalties include:

Offering an online money-gaming service: imprisonment extending to three years, a fine extending to ₹1 crore, or both;
Advertising an online money game: imprisonment extending to two years, a fine extending to ₹50 lakh, or both; and
Facilitating prohibited financial transactions: imprisonment extending to three years, a fine extending to ₹1 crore, or both.

Enhanced punishment may apply to repeat convictions under the provisions concerning the offering of online money-gaming services and facilitation of prohibited fund transfers.

These provisions must be applied prospectively in accordance with constitutional criminal-law principles. Conduct occurring before the relevant provision came into force requires examination under the laws operating on the date of that conduct.

When Does Illegal Online Betting Become a PMLA Case?

PMLA does not apply merely because money was deposited on an unlawful betting platform. The investigation must ordinarily identify criminal activity relating to an offence included in the PMLA Schedule.

Online betting investigations commonly originate from FIRs alleging scheduled offences such as:

Cheating and dishonest inducement;
Cheating by personation;
Criminal conspiracy connected with a scheduled offence;
Forgery of valuable documents or electronic records;
Use of forged documents or electronic records;
Extortion;
Corruption involving public officials;
Company fraud; or
A scheduled offence having cross-border implications.

The investigating agency may allege that users were dishonestly induced to deposit money, that withdrawal results were manipulated, that fictitious profit balances were displayed, that accounts were opened through forged KYC documents or that the betting operation formed part of a wider fraud and laundering syndicate.

Essential PMLA Questions

A defensible legal analysis should answer the following questions separately:

What is the exact scheduled or predicate offence?
Who allegedly committed that offence?
What property was derived or obtained from that criminal activity?
How was the alleged proceeds-of-crime figure calculated?
Which bank account, UPI ID, wallet or property received the identified amount?
Who legally owned and beneficially controlled that account or property?
What was the role and knowledge of the person under investigation?
Were lawful and allegedly tainted funds mixed together?
Was the person merely providing a legitimate service, or knowingly facilitating laundering?
What evidence supports concealment, possession, acquisition, use or projection as untainted?

Important: Illegal betting revenue is not automatically “proceeds of crime” for every PMLA purpose unless the required connection with criminal activity relating to a scheduled offence is legally established.

How Illegal Betting Proceeds Are Commonly Collected

An online betting platform may not display the real bank account of its overseas operator. Instead, deposits may be collected through multiple changing accounts and payment instruments.

The financial architecture may involve:

Individual savings accounts;
Current accounts of small businesses;
Accounts opened in the names of employees or domestic workers;
Accounts of dormant or shell companies;
Co-operative society accounts;
Fictitious merchant accounts;
UPI IDs;
Mobile wallets;
Prepaid payment instruments;
Payment-gateway settlement accounts;
Domestic Money Transfer facilities;
Cash collection agents;
Cryptocurrency exchanges;
USDT wallets;
Hawala channels; and
Overseas companies and fintech platforms.

Users may be instructed to transfer money to a different account for every deposit. The betting platform’s internal dashboard then credits a corresponding digital balance to the user.

The Typical Betting-Proceeds Fund Flow

A commonly investigated fund flow may appear as follows:

User deposit → UPI or bank account → mule account → collection account → payment gateway or shell entity → cryptocurrency or hawala conversion → offshore operator → commission distribution → property, bullion, securities or luxury assets.

The entire chain does not necessarily appear in one bank statement. ED may reconstruct it by combining data obtained from banks, payment platforms, devices, cloud accounts, crypto exchanges, company records and persons summoned under Section 50 of the PMLA.

Mule Bank Accounts and PMLA Exposure

A mule account is an account used to receive, temporarily hold or transfer funds for another person. In betting investigations, it may be opened through:

Stolen or fabricated KYC documents;
Documents collected from financially vulnerable individuals;
Promises of a monthly rental payment;
Commission for every transaction;
Employment or loan pretexts;
Misuse of a dormant company;
Control of the registered mobile number by another person; or
Remote access to internet-banking credentials.

When the Account Holder May Face Serious Exposure

Risk materially increases where evidence indicates that the account holder:

Knowingly supplied the account for betting collections;
Shared internet-banking credentials, OTPs or SIM access;
Received commission for the account’s use;
Regularly withdrew cash for the operator;
Transferred funds according to Telegram or WhatsApp instructions;
Opened multiple accounts for the same purpose;
Created false invoices to explain the credits;
Participated in cryptocurrency conversion;
Retained a share of the proceeds; or
Continued facilitating transfers after receiving warnings or complaints.

When an Account Holder May Have a Legitimate Defence

An account holder may have a materially different defence where:

The account was opened or operated through identity theft;
The registered mobile number was not under the holder’s control;
The holder did not receive or retain any commission;
The transactions were inconsistent with the holder’s normal financial profile;
The holder made an immediate bank or police complaint;
The holder had no access to the internet-banking credentials;
The credits were reversed or frozen before the holder used them;
The account was a genuine business account receiving apparently regular settlements; or
The beneficial operator can be independently identified through devices, IP logs and communications.

Ownership of an account creates an evidentiary connection, but it does not automatically establish knowing participation in money laundering.

UPI IDs, Payment Wallets and Merchant Accounts

UPI IDs and mobile wallets may be used to collect small-value deposits from large numbers of bettors. The collection account may be changed frequently to avoid detection or transaction limits.

Investigators may obtain:

UPI virtual payment addresses;
Linked bank-account details;
Registered mobile numbers;
Device identifiers;
IP addresses;
Merchant-category information;
QR-code creation records;
Transaction timestamps;
Settlement statements;
Chargeback and complaint records;
Beneficiary details;
API integration data; and
Communication between the merchant and payment provider.

A QR code described as belonging to a grocery store, consultancy, travel agency or software company may be examined where the transaction pattern indicates that its real use was betting collection.

Payment Gateways, Aggregators and Fintech Companies

A payment intermediary may receive an ED summons or become subject to search where the investigation alleges that its infrastructure was used to collect or layer betting proceeds.

The legal position depends substantially upon knowledge, due diligence, transaction monitoring and response to red flags.

Relevant Red Flags

Merchant turnover grossly exceeding the stated business profile;
Thousands of unrelated low-value deposits;
Rapid settlement to unrelated entities;
Frequent changes in beneficiary accounts;
Multiple merchants controlled through common devices or IP addresses;
Use of common KYC documents, email addresses or mobile numbers;
High chargeback or cybercrime-complaint rates;
Merchant websites having no genuine goods or services;
Transactions occurring during major sporting events;
Settlement to crypto exchanges or foreign intermediaries;
False invoices or non-existent counterparties; and
Continued processing after regulatory or banking alerts.

Potential Defence Material

A payment company should preserve:

Merchant-onboarding files;
Beneficial-ownership verification;
Website and application review records;
Risk-rating decisions;
Transaction-monitoring alerts;
Suspicious-transaction reporting records;
Internal escalation emails;
Settlement instructions;
Account-suspension decisions;
Responses to bank or law-enforcement notices;
Employee access logs; and
Contracts defining the actual service provided.

A company’s failure to detect misuse may create regulatory questions, but PMLA criminal liability requires examination of the statutory requirement of knowing assistance or actual involvement with proceeds of crime.

Cryptocurrency and USDT in Online Betting Investigations

Betting operators may convert collected funds into Bitcoin, Ether, USDT or another Virtual Digital Asset. Stablecoins are frequently examined because they can transfer value across borders with comparatively limited price volatility.

The investigation may attempt to establish:

Which bank account purchased the VDA;
Which exchange account was used;
Whose KYC was submitted to the exchange;
Which external wallet received the withdrawal;
Whether the wallet was custodial or non-custodial;
Whether the assets moved through multiple wallets;
Whether a P2P sale converted the VDA back into rupees;
Whether the wallet transferred funds to an overseas exchange;
Whether a bridge or decentralised exchange was used; and
Whether the resulting funds purchased property or other assets.

Public blockchain data may reveal the movement of cryptocurrency. It does not, by itself, conclusively identify the legal owner or controller of every wallet. Wallet attribution ordinarily requires exchange KYC, devices, private-key material, chats, IP logs, saved addresses, P2P records or corresponding bank transactions.

Shell Companies and Layering Entities

Betting proceeds may be routed through companies that ostensibly carry on:

Software development;
Digital advertising;
Tour and travel services;
E-commerce;
Consultancy;
Event management;
Media buying;
Financial technology;
Import and export;
Online education; or
Marketing and lead generation.

ED may examine whether the entity had:

A functioning business office;
Genuine employees;
Real customers;
Corresponding invoices and deliverables;
Tax-compliant revenue;
Commercially reasonable margins;
Independent directors and beneficial owners;
Control over its bank accounts;
Genuine contractual counterparties; and
A lawful explanation for onward transfers.

An invoice does not conclusively establish a genuine transaction where the alleged service was never provided or the money was returned through cash, hawala, crypto or another layered entity.

Panel Operators and Betting Affiliates

Illegal betting syndicates may operate through “panels,” “branches,” “master IDs” or “affiliate accounts.” A panel operator may be responsible for:

Creating user IDs;
Setting deposit and withdrawal limits;
Providing bank or UPI details;
Managing balances;
Settling winnings;
Recruiting bettors;
Maintaining ledgers;
Arranging cash withdrawals;
Managing local mule accounts; and
Sending the operator’s share through hawala or cryptocurrency.

Relevant evidence may include admin-panel access logs, user ledgers, Telegram groups, betting sheets, commission calculations, domain credentials, customer chats and recovery of betting applications from seized devices.

Influencers, YouTubers and Celebrity Endorsements

The legal exposure of an influencer cannot be determined merely from the fact that a promotional video existed. The complete relationship must be examined.

Important questions include:

What platform was promoted?
Was the promotion direct or disguised as a sports-news or gaming advertisement?
Was a betting link, referral code or QR code provided?
Was the campaign targeted at users located in India?
Who negotiated and approved the campaign?
What representations were made about legality, withdrawals or guaranteed returns?
Was the payment fixed, performance-based or linked to user deposits?
Did the influencer receive cash, bank transfer, cryptocurrency or foreign remittance?
Was the payment received from the platform, an advertising agency or a shell entity?
Were invoices, GST and income-tax records maintained?
Did the influencer continue promoting the platform after official warnings?
Was the influencer involved only in advertising, or also in collections and settlements?

Direct Exposure under the Online Gaming Act

Section 6 of the Promotion and Regulation of Online Gaming Act, 2025 is broad enough to cover direct and indirect promotional involvement. Section 9(2) provides punishment extending to two years’ imprisonment, a fine extending to ₹50 lakh, or both, for advertisements made in contravention of Section 6.

When PMLA Exposure May Be Alleged

PMLA exposure becomes a separate issue where ED alleges that an influencer:

Knew that the platform generated proceeds through scheduled criminal activity;
Received promotional payments directly from identified proceeds of crime;
Accepted payments through mule accounts or hawala;
Converted promotional proceeds into cryptocurrency;
Participated in layering or concealment;
Created false invoices or contracts to project the payment as legitimate;
Received a percentage of deposits or losses generated through referred users;
Provided access to accounts, entities or wallets for collection purposes;
Acquired assets from the identified proceeds; or
Continued assisting the operation after acquiring knowledge of its unlawful structure.

Why Promotion Alone Does Not Automatically Establish Money Laundering

An advertisement offence and a PMLA offence have different statutory ingredients. For PMLA, the agency must still establish the proceeds-of-crime foundation and the role attributed to the influencer in a process or activity connected with that property.

A fixed promotional fee received through a disclosed banking channel under a genuine agency contract may require investigation, but it is not automatically equivalent to knowing participation in laundering.

Documents an Influencer or Advertising Agency Should Preserve

Campaign agreement;
Agency correspondence;
Client-onboarding and due-diligence records;
Brand ownership details;
Campaign brief and approved script;
Content publication dates;
Target-location and geo-targeting instructions;
Referral-code records;
Affiliate dashboard statements;
Invoice and GST records;
TDS certificates;
Bank statements showing receipt of fees;
Foreign-remittance documents;
Cryptocurrency transaction records, where applicable;
Communications concerning deletion or suspension of the campaign;
Evidence showing whether the influencer controlled user deposits;
Evidence showing whether payment depended upon user losses or deposits; and
Legal or compliance advice obtained before publication.

Deleting content, chats, devices or financial records after learning of an investigation may create additional evidentiary complications.

Recent ED Action Involving an Influencer

In a press release dated 5 January 2026, the Directorate of Enforcement stated that its Kolkata Zonal Office had conducted searches at locations in Delhi, Mumbai, Surat, Lucknow and Varanasi in an illegal online betting and gambling investigation linked with a social-media influencer and YouTuber.

ED alleged that illegal betting platforms had been promoted, that proceeds were received through hawala channels and mule accounts, and that assets were acquired from such proceeds. The release referred to seizure or freezing of vehicles, cash, insurance policies, fixed deposits, bank balances and digital devices.

The allegations contained in an ED press release remain subject to adjudication and proof before the competent court. A press release is not a final judicial determination of guilt.

Advertisement Networks and Sports Applications

Betting advertisements may be delivered through:

Sports-score applications;
Cricket-content websites;
Video-streaming platforms;
Programmatic advertising systems;
Affiliate networks;
Foreign media-buying companies;
Surrogate sports-news brands;
Telegram channels;
Push notifications;
Social-media reels and stories; and
Influencer-specific referral links.

ED may seek advertisement-booking records, campaign dashboards, geo-targeting settings, click-through data, billing records, advertiser identities, revenue sharing and server logs.

In a March 2026 press release concerning 1xBet, ED referred to structured advertisement arrangements and geo-targeted execution of advertisements through sports-related platforms. The agency also referred to promotional networks, payment channels and assets attached during the investigation.

Recent ED Pattern: Accounts, Crypto and Offshore Movement

A July 2026 ED press release concerning an online betting, gaming and investment-fraud investigation described an alleged structure involving:

Collection of money from victims;
Routing through mule accounts and layering entities;
Use of a fintech company’s accounts;
Numerous cybercrime complaints;
Conversion into Virtual Digital Assets;
Movement to offshore persons or entities;
Use of fabricated KYC documents; and
Freezing of multiple bank accounts.

The agency stated that an account or wallet on a crypto platform had allegedly been opened using KYC and fabricated documents connected with a co-operative society and that a substantial fund flow had been routed through the relevant bank account.

This example shows why bank ownership, beneficial control, fabricated KYC, wallet attribution and the transaction trail must be analysed separately.

Mahadev Online Book Investigation: Large-Scale Layering Pattern

ED’s public material concerning the Mahadev Online Book investigation describes an alleged international betting syndicate operated through a franchise-based panel network.

The agency has publicly alleged that proceeds were layered through thousands of mule or dummy accounts, transferred outside India through hawala and cryptocurrency, and invested in movable and immovable properties in India and the UAE.

A March 2026 press release stated that total attachment, seizure and freezing in that investigation had reached approximately ₹4,336 crore at that stage. Those figures and allegations represent the investigating agency’s public account and remain subject to the applicable adjudicatory and judicial proceedings.

How ED Reconstructs the Betting Money Trail

ED may combine the following evidence:

FIRs and cybercrime complaints;
Victim bank statements;
UPI and wallet transaction records;
Payment-gateway settlement statements;
Merchant onboarding and KYC records;
Bank-account opening forms;
Internet-banking and device logs;
SIM and mobile-number records;
IP-address information;
Company beneficial-ownership records;
GST invoices and returns;
Income-tax records;
Betting-panel ledgers;
Admin-dashboard access;
WhatsApp and Telegram chats;
Email communications;
Crypto exchange KYC;
Wallet addresses and transaction hashes;
Hawala ledgers;
Cash-withdrawal patterns;
Property-purchase records;
Vehicle and insurance records;
Statements recorded under Section 50 PMLA; and
Material recovered during search proceedings.

ED’s Principal Powers in an Online Betting Investigation

Section 50: Summons

ED may summon a person to give evidence or produce records. An influencer, account holder, company director, payment intermediary, accountant, advertiser, wallet holder or panel operator may receive a summons.

The person should identify the exact capacity in which the summons has been issued and reconcile the relevant financial records before appearance. A speculative or inaccurate explanation may later be compared with bank, device, exchange and platform data.

Section 17: Search, Seizure and Freezing

ED may search premises and seize records or property where the statutory requirements are asserted to exist. Where physical seizure is impracticable, property may be frozen under the applicable statutory process.

In an online betting investigation, the searched or frozen material may include:

Bank accounts;
Payment wallets;
Merchant balances;
Cryptocurrency exchange accounts;
Hardware wallets;
Mobile phones and laptops;
Vehicles;
Insurance policies;
Fixed deposits;
Securities;
Digital advertising accounts;
Social-media accounts;
Domain and server credentials; and
Betting-panel records.

Section 5: Provisional Attachment

ED may provisionally attach property where the statutory conditions are claimed to be fulfilled. The attachment may concern the direct property alleged to be proceeds of crime or other property claimed to represent equivalent value under the applicable legal principles.

Section 8: Adjudication

The Adjudicating Authority considers the statutory complaint and the response of the affected party. The reply should ordinarily address ownership, source of funds, transaction trail, role, knowledge, valuation and the scheduled-offence nexus.

Section 19: Arrest

Arrest under Section 19 is a separate statutory action requiring compliance with the conditions and safeguards prescribed by the PMLA.

Section 45: Bail

PMLA bail is governed by Section 45, including the twin conditions, subject to applicable constitutional principles, statutory exceptions and the specific evidentiary record.

Defence of a Frozen Bank Account

A representation or legal challenge concerning a betting-related account should not be limited to the statement that the account holder is innocent. It should provide a transaction-specific explanation.

Relevant material may include:

Account-opening documents;
Proof of the holder’s occupation or business;
Normal turnover records;
Invoices and contracts;
Identity of authorised account operators;
IP and device-control information;
Explanation of each disputed credit;
Proof that funds were not withdrawn or retained;
Prior complaints made to the bank or police;
Proof of identity theft or credential misuse;
Salary and household-expense requirements;
Tax liabilities and statutory payments;
Details of legitimate funds mixed with the disputed amount; and
A request for segregation or limited operation where legally maintainable.

The date of freezing, statutory authority, amount frozen, communication issued to the bank and subsequent application before the Adjudicating Authority should be verified.

Defence Against Attachment of Property

An attachment should be tested against:

The scheduled offence relied upon;
The identified proceeds-of-crime amount;
The actual money trail;
The date of acquisition of the property;
The lawful source of purchase funds;
Independent ownership of a spouse or family member;
Whether the property predates the alleged offence;
Whether equivalent-value attachment has been properly invoked;
Whether the valuation is correct;
Whether legitimate and allegedly tainted funds have been indiscriminately combined; and
Whether the statutory procedure and timelines were followed.

Remedies Against Freezing or Attachment

Depending upon the procedural stage and nature of the order, the remedies may include:

A detailed representation to the investigating officer;
Submission of source-of-funds documents;
Request for release of unrelated devices or accounts;
Request for segregation of legitimate balances;
Reply before the Adjudicating Authority;
Application concerning essential business or statutory payments;
Appeal before the Appellate Tribunal under Section 26;
Appeal before the competent High Court under Section 42; and
Appropriate constitutional or criminal proceedings where maintainable on the specific facts.

An appeal under Section 26 is ordinarily required within forty-five days from receipt of the Adjudicating Authority’s order, subject to the Tribunal’s statutory power concerning sufficient cause.

An appeal under Section 42 is ordinarily required within sixty days from communication of the Appellate Tribunal’s decision. The statute permits a further period not exceeding sixty days where sufficient cause is established.

Preparation for a Section 50 Summons

The person summoned should prepare a factual chronology covering:

Relationship with the relevant platform or company;
Dates of account opening and closure;
Access to mobile numbers and devices;
Nature of services provided;
Campaign or affiliate arrangements;
Bank accounts and wallets used;
Payments received;
Invoices issued;
Tax treatment;
Onward transfer or utilisation of funds;
Knowledge of the platform’s operations;
Warnings or complaints received;
Termination of the relationship; and
Documents supporting each material statement.

No person should create retrospective records, alter chats, delete devices, move disputed assets or provide an explanation that is inconsistent with the original digital and banking records.

Role-Specific Defence Matrix

Account Holder

Establish beneficial control, knowledge, retention of funds, communication with operators and whether the account was knowingly supplied.

Influencer or Celebrity

Examine campaign terms, due diligence, content, referral links, payment structure, source of remuneration and whether the person participated beyond advertising.

Advertising Agency

Produce client onboarding, insertion orders, media plans, invoices, campaign instructions, geo-targeting records and proof of the agency’s limited role.

Payment Gateway or Fintech Company

Produce merchant KYC, risk monitoring, alert escalation, settlement data, suspicious-transaction reporting and evidence showing whether the company knowingly facilitated betting transactions.

Company Director

Establish actual responsibility, decision-making authority, access to accounts, beneficial ownership and the statutory requirements governing offences by companies.

Crypto Wallet Holder

Prepare wallet attribution, exchange KYC, transaction hashes, source of crypto, P2P records and evidence identifying the person who controlled the private key.

Property Holder or Family Member

Prove independent income, acquisition date, ownership, payment trail and absence of beneficial holding for the alleged betting operator.

Frequently Asked Questions

Does every illegal betting case automatically become a PMLA case?

No. PMLA ordinarily requires criminal activity relating to a scheduled offence and identifiable proceeds of crime. A betting-law violation and a PMLA offence must be analysed separately.

Can ED freeze a bank account that received betting-related money?

ED may freeze an account where the statutory conditions are asserted to exist. The legality, scope, amount and continuation of the freeze can be examined through the applicable PMLA procedure.

Is a mule-account holder automatically guilty?

No. Knowledge and beneficial control are important. A person who knowingly rents an account, shares OTP access and receives commission stands differently from a victim whose KYC or credentials were stolen.

Can an influencer be prosecuted for promoting an online betting application?

Section 6 of the Promotion and Regulation of Online Gaming Act, 2025 prohibits direct and indirect advertisements promoting online money games. Section 9(2) prescribes imprisonment extending to two years, a fine extending to ₹50 lakh, or both.

Does promotion automatically make an influencer guilty of money laundering?

No. PMLA requires an identifiable proceeds-of-crime nexus and the statutory form of knowing assistance, involvement, possession, acquisition, use, concealment or projection. The advertising offence is legally distinct.

Can an influencer’s promotional fee be attached?

It may be examined or attached where ED alleges and supports a case that the fee represents proceeds of crime or property involved in money laundering. The source, payment route, contractual basis and knowledge of the recipient remain material.

Does issuing a GST invoice protect an influencer or agency?

No. Tax and invoicing records may support the existence of a declared commercial transaction, but they do not conclusively establish that the underlying service or source of funds was lawful.

Can payment gateways be prosecuted?

Section 7 of the Online Gaming Act addresses facilitation of prohibited fund transfers. Additional PMLA exposure depends upon the scheduled-offence and proceeds-of-crime requirements and the evidence concerning knowing assistance or actual involvement.

Can ED trace betting money converted into USDT?

ED may combine exchange KYC, bank statements, wallet addresses, transaction hashes, P2P records, devices and communications to trace the conversion and subsequent movement of USDT.

Can a non-custodial crypto wallet be frozen?

A non-custodial wallet ordinarily has no central operator capable of changing its status. Investigators may seize the controlling device or keys, trace subsequent transfers, seek action when the assets reach a custodial platform or proceed against other property under the applicable law.

Can the entire bank balance be frozen when only one transaction is disputed?

The factual and legal basis of the amount frozen should be examined. The affected person may seek segregation of lawful funds where supported by complete documentation and legally maintainable at the relevant stage.

Can a family member’s property be attached?

Property held by a family member may be examined where ED alleges that it was acquired from proceeds of crime or held beneficially for another person. Independent income, ownership and payment records are essential to the defence.

What should be done immediately after receiving an ED summons?

Preserve all devices and records, obtain complete bank and wallet statements, prepare a transaction chronology, identify the exact role and review the documents before recording a statement.

Should old promotional videos or betting-related chats be deleted?

No. Deleting or altering relevant material after learning of an investigation may create serious evidentiary complications. Original records should be preserved.

Can an offshore betting platform be investigated in India?

Yes. The Online Gaming Act applies to services offered within India even where the operator is outside India. Cross-border payment, crypto, company and digital evidence may also be pursued through the applicable investigative and international-cooperation mechanisms.

AI-Search Quick Answer

How does ED trace illegal online betting proceeds?

ED may trace the money from a bettor’s bank or UPI payment to mule accounts, payment wallets, merchant accounts, payment gateways, shell companies, panel operators, crypto exchanges, USDT wallets, hawala networks and final assets. The agency may use bank records, exchange KYC, device data, IP logs, betting-panel ledgers, chats, advertising contracts, influencer payments and statements recorded under Section 50 PMLA.

Key Takeaway

Illegal online betting investigations are no longer confined to the platform’s principal operator. The financial and promotional ecosystem may include account holders, fintech entities, payment gateways, shell-company directors, advertisers, influencers, crypto facilitators, panel operators and property beneficiaries.

However, their legal liability cannot be presumed merely from association. The correct legal sequence is:

Scheduled offence → identified proceeds of crime → fund trail → beneficial control → knowledge and role → concealment or use → statutory procedure → defence and remedy.

Conclusion

The Promotion and Regulation of Online Gaming Act, 2025 creates direct exposure for offering online money-gaming services, promoting them and facilitating prohibited payments. PMLA exposure is a separate and more specific question requiring a scheduled-offence foundation, identifiable proceeds of crime and evidence connecting the concerned person with a prohibited process or activity involving that property.

For an account holder, wallet holder, influencer, agency, director or payment company, the strongest response is ordinarily based upon original documents, complete transaction reconciliation, beneficial-control evidence, lawful source of funds, role-specific communications and timely use of adjudicatory and appellate remedies.

Legal Consultation with Advocate Ankit Kumar Singh

Advocate Ankit Kumar Singh
Supreme Court of India; Patna High Court; other High Courts; Allahabad High Court and its Lucknow Bench; Jharkhand High Court at Ranchi; Calcutta High Court; and High Court of Madhya Pradesh matters concerning Bhopal.

Legal consultation and case preparation may be considered in matters involving illegal online betting proceeds, ED summons, mule bank accounts, UPI and payment-wallet freezing, crypto and USDT tracing, influencer promotions, affiliate payments, payment-gateway investigations, property attachment, adjudication, PMLA appeals, arrest and bail.

Contact: 8294431232
Email: ankitsingh.legum@gmail.com
Website: advocateankitkumarsingh.in

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No judicial, investigative or administrative result can be guaranteed. Legal strategy depends upon the scheduled offence, banking records, digital evidence, fund trail, role attributed to the person and procedural stage of the individual case.

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Legal Information Note: This article provides general legal information. It does not constitute legal advice concerning any particular platform, bank account, wallet, influencer, company, summons, freezing order, attachment, arrest or prosecution.