**Mumbai: Enforcement Directorate Flags Surrogate Advertising in Online Betting Platforms**
The Enforcement Directorate (ED), during its investigation into multiple online betting platforms, has uncovered a growing trend of surrogate advertising used to promote these applications despite strict regulatory restrictions. According to investigators, offshore betting app Parimatch and other similar entities have been engaging social media influencers, cricketers, and Bollywood actors to increase brand visibility through indirect promotions.
### Modus Operandi of Promotion and Money Laundering
Officials revealed that the modus operandi involves a combination of celebrity endorsements, influencer marketing, domestic “mule” banking conduits, payment aggregators, domestic money transfer (DMT) channels, and cryptocurrency conversions. This complex approach aims to keep Indian users engaged while ensuring a continuous revenue stream into the illegal betting ecosystem.
### Online Gaming Bill Introduces Anti-Betting Provisions
In August, the Indian Parliament passed the Promotion and Regulation of Online Gaming Bill, 2025. This legislation includes anti-betting provisions designed to ban online money games due to their links to addiction, financial ruin, and social distress.
### ED Raids Freeze Rs 110 Crore; Seizes Mule Credit Cards
During raids conducted at 17 locations the same month, the ED froze Rs 110 crore parked in mule accounts and seized 1,200 mule credit cards. The agency also discovered that Parimatch had established Indian entities under the names Parimatch Sports and Parimatch News to run surrogate advertisements.
### Front Entities Disguised as News Outlets and Fan Clubs
Officials involved in the investigation disclosed that offshore platforms like Parimatch and 1xBet heavily rely on surrogate advertising to target Indian audiences despite gambling promotion restrictions. These companies operate Indian-facing entities with neutral names such as *Parimatch News* or *Parimatch Sports*, masquerading as sports news outlets, fan clubs, or merchandise brands.
These front entities sign endorsement deals with cricketers, B-list actors, and social media influencers, who promote the brand as lifestyle content, sports updates, or fan communities. An official noted, “Payments to these individuals typically originate from entities based in Cyprus, Dubai, and similar jurisdictions.”
The Indian-facing brands are deliberately crafted to closely resemble the original betting apps, facilitating seamless brand recall when users encounter them online. This strategy effectively funnels audiences toward the actual offshore betting platforms.
### Celebrity Endorsements and Influencer Marketing Tactics
Once established, these surrogate brands engage celebrity endorsements and influencer campaigns. Cricketers, B-list film actors, and social media personalities are enlisted to promote what appears to be sports content, lifestyle collaborations, or merchandise launches.
To avoid direct gambling references, messaging is carefully crafted with vague hooks such as “check out my collab” or “follow this sports page.” Meanwhile, branding remains prominent through logos, hashtags, and visuals aligned with the betting platforms.
Additional strategies include merchandise launches, contest announcements, and prediction polls that build audience engagement and add legitimacy. Curious users searching for these brands or scanning links are redirected to offshore betting platforms or mirror sites where actual wagering occurs.
### Event Sponsorships and Digital Saturation Strategy
The surrogate advertising model also thrives through event sponsorships and content integration. Front brands sponsor cricket tournaments, web shows, and OTT content to secure banner placements and on-screen mentions.
They maintain a strong digital presence by operating YouTube channels, Instagram pages, and sports blogs featuring match previews, fan polls, and highlight reels—drawing sports enthusiasts under the guise of news or analysis.
Embedded within this content are QR codes, swipe-up links, and short URLs directing users to download pages or mirror websites of the betting apps.
A key strength of this strategy is its digital saturation. Coordinated influencer posts, regional-language campaigns, hashtag challenges, and micro-influencer pushes flood social media feeds and search engines. Repetition normalizes the brand name and primes users to search for it during major sporting events like the IPL or international cricket tours.
Once users actively search for the brand, they are effortlessly redirected from benign websites to actual offshore betting platforms.
### Resilient Tactics to Evade Detection
To sustain their reach and avoid regulatory takedowns, surrogate advertisers employ resilient tactics such as rotating social media accounts, creating mirror landing pages, and pushing users into closed groups on platforms like Telegram and WhatsApp, where more direct links are shared.
They often disguise campaigns under social good initiatives or community activities, occasionally sponsoring charity drives, sports festivals, or athlete outreach programs to appear legitimate.
In some cases, archived endorsements, old content, or celebrity lookalikes are used to keep associations alive while minimizing fresh exposure.
### Blurring Lines Between Sports Marketing and Gambling Promotion
Ultimately, the surrogate advertising strategy blurs the line between legitimate sports marketing and covert gambling promotion. It combines celebrity appeal, sports fandom, and clever branding to keep betting platforms highly visible to Indian users without explicitly declaring themselves as gambling apps.
This playbook gives offshore operators a wide funnel of new users while shielding the campaigns through layers of plausible deniability.
Officials explained that the modus operandi rests on two pillars: surrogate advertising on the front end, and money laundering on the back end.
### Money Laundering Cycle
User deposits are collected across numerous mule bank accounts opened under shell companies or individuals. These funds are layered through bogus vendor payments, e-commerce refunds, or chargebacks to disguise their origin.
A portion of the funds is withdrawn in cash and passed on to hawala operators, while another portion is converted into cryptocurrencies like USDT via overseas wallets, effectively moving money outside India’s formal banking system.
### Offshore Apps Generating Thousands of Crores
According to ED officials, this combination of surrogate advertising upfront and elaborate laundering processes at the backend has allowed offshore betting apps to generate thousands of crores in revenue from Indian users while masking both their promotional activity and financial flows.
Offshore betting companies are estimated to generate more than Rs 85,000 crore annually from India.
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