Betting has moved past mule accounts. Now it runs on UPI

[Prakat]

Betting has moved past mule accounts. Now it runs on UPI

Meity cracked down on VPNs last month. But India’s newest gambling platforms, like 99 Exchange and 11xplay, work on architecture the system cannot see

by Mrunmayee Kulkarni

 

 

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There are two things most Indians love: cricket and giving advice. The IPL season combines them. 

 

At least that’s what the last Bengaluru vs Hyderabad match showed me. Men in RCB jerseys on the couch, watching men in RCB jerseys on a screen with bated breath, calling out suggestions: “Just play singles da, why are they risking hitting a six?”

 

Everyone in the room had a guess as to what the final score would be. “It’s a prediction,” one of them corrected me. “I watch matches all the time. I think I can tell what’s going to happen next.” He was right. The final score was within five runs of his estimate. 

 

It is a truth universally acknowledged that if you are a millennial, you try to monetise any skill you are even a little bit good at. Most gamblers begin this way: if I can call this match, why not stake some cash on it?

 

Betting is illegal in India. It is also ubiquitous and inseparable from the country’s religion of cricket. And by conservative estimates, a $20 billion industry. 

 

For years, that money moved through the predictable architecture of crime. Offshore platforms based in Cyprus and Curaçao. Mule accounts—bank accounts opened in someone else’s name, or hijacked from someone who wanted fast cash through a suspiciously easy job—that received gambling deposits and forwarded them up a chain to corporate accounts the operators controlled. 

 

Gambling platforms, however, have gone a step beyond mules, even beyond foreign websites that can be accessed with VPNs. 

Betting today runs on trust, direct peer-to-peer transactions on our famed UPI. There is no mule network the authorities can track, or unsuspecting victims who would make a complaint about strange transactions in their accounts. 

There is just one gambler paying another, on rails the government built for groceries and rent.

 

The new satta bazaar

 

It took a friend of a friend to get me onto one of these platforms. “Do not share this with anyone,” he warned me before sharing a phone number. 

 

I was to text the stranger who would add me to a Whatsapp group. It would have a website link, along with a temporary ID and password to log in. The vouching chain is how the platform manages who gets a working account—and who, by extension, can be held responsible if a new user turns out to be a problem.

 

The Whatsapp group sent me to a site called 99 Exchange, which runs at 99exch.live. The same operation runs at least two sister sites: laser247.club and 11xplay.pro. All of them are marketed under one brand: Bet Bhai Book, or BBB. 

 

There is also a 39,000-subscriber Telegram channel, an Instagram page, and customer-service Whatsapp lines that anyone can find with a Google search. What it does not do is take new users off the open internet. Discovery is open. Access is not. 

99 Exchange’s homepage looked like every offshore betting site ever, with tabs for cricket, tennis, horse racing, matka, and even the stock market. What’s new is how your money is handled, starting with a deposit. 

 

The deposit page has very specific guidelines and a bunch of UPI IDs to choose from.

 

“All of these are other users,” said TS, a coder who had worked for a similar platform. “These are people who are withdrawing money at the same time you are depositing.”

 

The platform, he said, was running a matching engine in the background. So when I clicked “deposit” for Rs 2,000, the engine searched its queue of pending withdrawal requests, found users who together wanted to withdraw that amount, and showed me their UPI IDs. I might pay one user the full Rs 2,000. I might pay four users Rs 500 each. The split depended on what the engine found in its queue.

When I sent the money, those strangers got UPI notifications. As far as their banks knew, a stranger had paid them. As far as my bank knew, I had paid strangers. There was no record anywhere—at either bank, or on the UPI’s settlement layer—that the transaction had anything to do with gambling, or with 99 Exchange, or with each other.

 

To complete the loop, I just had to upload UPI screenshots on 99 Exchange with the unique transaction number visible.

“The platform never touches a rupee from these user-to-user deposits or withdrawals,” TS said. “It just watches the transaction clear and updates two numbers on its own books.”

 

With my “deposit”, my wallet went up by Rs 2,000. The withdrawing users’ wallets, which were debited the moment they clicked “withdraw”, were now marked “paid”. The ledger balanced.

 

So how does the platform make money? 

 

“Two ways,” TS explained. “Advertisements on the websites (usually about other real money games) and platform fees.”

Every time a user places a bet from their wallet, a small transaction fee is skimmed off the top. 

 

A Rs 500 bet on RCB, for example, is actually a slightly smaller bet, with the difference credited to the platform’s internal ledger as a wallet balance the operators control. By the above-mentioned source’s estimate, nearly Rs 20 lakh moves through platforms like these every day. 

Neither of these revenue streams shows up in a bank account. They are numbers in the platform’s database, credits that the operators still have to turn into real money.

 

“That’s where it gets interesting,” TS said. To pull those profits out, the platform occasionally routes incoming deposits into a single core account that the operators control—the same account that also acts as a liquidity buffer when the matching engine cannot find a clean pair. The core account rotates regularly. No single bank account is allowed to accumulate enough volume to attract attention.

From there, TS added, the money goes into various channels, often ending up in cryptocurrency wallets held offshore. That is where the operators’ actual profits sit.

 

The fee skim is the only money that ever leaves India. Everything else, from the deposits to the withdrawals, stays inside the country, moving from one Indian’s bank account to another’s.

Looking for the wrong trail

To understand why this is new, you have to remember how the old system worked.

 

Think of Cyprus-based betting apps like Parimatch and 1Xbet, which the Enforcement Directorate (ED) has been chasing for two years. 

A gambler deposits money. The money lands in a mule account—somebody else’s bank account, opened by a person recruited through a Telegram ad promising easy cash, or simply hijacked using stolen Aadhaar details. The said account collects deposits from many gamblers. Once enough money has built up, the mule sends it on to a larger account that the betting operator actually controls. From there, the operator converts the money into cryptocurrency and moves it abroad. The mule who lent his account gets paid a small cut.

 

This is a funnel. Many gamblers feed a smaller number of mules, who feed an even smaller number of operator accounts, which then send the money out. The architecture is simple. At every step, money gets more concentrated.

 

That is exactly what India’s enforcement machinery is built to find. The ED’s job is to follow the funnel up to the operator and freeze each account along the way. 

 

The Reserve Bank of India’s innovation hub has built an AI tool called Mulehunter—now used by 23 banks—that scans for patterns that mules show but ordinary people do not. Many small deposits from strangers, followed by one big outgoing transfer to the same account, again and again. Sudden bursts of activity followed by long periods of nothing. Money sitting in an account for only a few minutes before moving on. There are 19 such signals Mulehunter is trained to flag. 

 

And it has worked. In August 2025, the ED raided 17 locations across the country in the Parimatch case, froze Rs 110 crore parked in mule accounts, and seized 1,200 mule credit cards. The agency found that Parimatch had laundered over Rs 3,000 crore in a single year. In a separate 1Xbet investigation, the ED traced Rs 331 crore that had passed through the bank account of a Rapido bike driver in Delhi—a man living in a two-room shanty who had no idea his account was being used. 

 

But all of these successes had the same assumption. “The whole enforcement system works because the funnel has a shape, and that shape leaves a trail,” a former cybercrime official told me. “The newer platforms do not have that shape.”

The silence holds

Betting markets that live on trust and complicity are an old Indian institution. 

 

Matka, the numbers racket that ran out of Bombay’s mills in the 1960s and 70s, worked on much the same principles—a closed network of bookies and runners, vouched-in punters, daily settlement in cash. There was a code of silence tight enough that the state could harass the trade for decades without ever really breaking it. Ratan Khatri’s matka empire was illegal, ubiquitous, and mostly tolerated. It survived because nobody inside it had any reason to talk to anyone outside.

 

Over six decades later, this betting platform works on similar lines. The bookies and runners are gone, but the vouching is still there, and so is the secrecy. It is omertà, in a way. Not because the gamblers are afraid to talk, but because there is genuinely nothing to report. 

 

We didn’t dupe anyone. We never stole an Aadhaar or hacked an account.

TS, a coder

 

Every rupee on the platform belongs to someone who chose to put it there, betting on a match they wanted to bet on, on terms they understood. When they lose, they lose. When they win, they get paid—in parts, across the day, by strangers whose names they never learn.

What the state has lost, however, is essentially the ability to moralise against such platforms. The Promotion and Regulation of Online Gaming Act (PROGA) of 2025 banned all online real money gaming in India. It was sold as consumer protection, to keep citizens from predatory operators exploiting vulnerable users. 

 

On these new betting sites, however, that moral structure is absent. The operators run infrastructure for gamblers who want to gamble, and take a cut. The architecture has produced an illegal economy that, by every metric except the law itself, behaves like a legal one.

In 99 Exchange’s FAQ section, the answer to its own question of legality is that laws in India vary by state, advising users to check “local regulations before using any betting platform”.

 

But that is not the same as saying it is safe. The system runs on trust, and unlike a bank, if 99 Exchange goes dark tomorrow, every gambler with money in a wallet has no one to call. Being a willing participant doesn’t absolve anyone of the risk.

 

The country has always had a gambling market, and the only thing that changes from one generation to the next is where it operates. Khatri’s matka ran out of mill chawls. Phalodi’s bookmakers ran out of a small town near Jodhpur. 

 

Everyday prediction markets are part of the same shadow. The Ken had reported earlier how Indians are placing crores on the Polymarket via VPNs, settled in dollar stablecoins outside the rupee economy. The government is now cracking down, with Meity tightening the VPN rules. 

But none of this enforcement touches the platform I deposited Rs 2,000 on. Today’s gambling rooms operate on people’s phones, getting people in via word of mouth and messaging apps. The question, increasingly, is not stricter enforcement. It is whether banning the platforms was ever going to stop the betting, or whether it just changed where the money hides.

 

Source: The Ken https://the-ken.com/newsletter/make-india-competitive-again/betting-has-moved-past-mule-accounts-now-it-runs-on-upi/