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Dedicated to the memory of every Federal, State, and Local law enforcement officer
killed fighting the production, transport, and sale of illegal drugs.
Drug Traffickers Can Use Internet Poker to Launder Money
Internet poker is a nearly perfect way to simultaneously launder and move criminally obtained money.

NOTICE: The technology and instructional material distributed from this website is intended for
use by law enforcement officials, policy makers, and researchers ONLY. PoliticsOfPoker.com
DOES NOT ADVOCATE the actual deployment of the technology as a cheating or money
laundering platform.

PoliticsOfPoker.com reminds visitors that although the US Department of Justice (DOJ), through
the FBI, has unambiguously declared that cheating at internet poker is not illegal, money
laundering is ALWAYS illegal regardless of the mechanism. A letter describing the DOJ position
from the FBI's Cyber Division to House Financial Services Committee ranking member Spencer
Bachus is available for download from PoliticsOfPoker.com. United States laws governing money
laundering can be studied at http://uscode.house.gov.

PoliticsOfPoker.com exists to alert internet poker players, law enforcement officials, and policy makers
to the severe money laundering danger inherent in internet poker. So far, this issue is absent from the
debate over legalization in the US. Legalization proponents argue that there are many jurisdictions
outside the United States with laws in place that regulate legal internet poker websites. That these laws
exist is irrelevant since they do not require policies, processes, and technologies that could help detect
illicit activity and prevent organized criminals from employing a spectacularly effective money
laundering method.

The demonstration technology available for download and study from PoliticsOfPoker.com proves that
no regulatory scheme currently in place can reliably detect international drug trafficking organizations
employing 'industrial-scale' operations to collect, concentrate, and transport illicitly obtained money
into and out of any country where internet poker is a lawful activity.

If one considers the characteristics of a drug trafficking operation, the utility of internet poker becomes
obvious. At the retail level, street dealers receive relatively small amounts of cash. The ideal money
laundering system would enable the dollars to be concentrated into larger non-cash pools in a way that
is traceable only in the context of antes, folds, calls, and raises made across a virtual poker table. At the
same time money is concentrated, it can be moved across international borders - all outside the
conventional, global banking system. The 'Internet Poker Cannot be Effectively Regulated' section
explains the cross border transfer dilemma in more detail.

From the first hand of the first internet poker game, dirty money can be transferred from one launderer
to another. The disbursal efficiency of internet poker ensures that this dirty money can be split across

Copyright (c) 2010, PoliticsOfPoker.com

 PoliticsOfPoker.com
Dedicated to the memory of every Federal, State, and Local law enforcement officer
killed fighting the production, transport, and sale of illegal drugs.
many tables and hands with amazing speed. In fact, the vulnerability becomes geometrically more
difficult to track as more people, at a given moment in time, are playing internet poker. In other words,
the larger the internet poker player community becomes, the deeper an industrial-scale money
laundering operation can be hidden among thousands of virtual tables and millions of poker hands.

Internet poker website operators claim that software exists that can detect collusion and the subsequent
movement of dirty money across virtual poker tables. This assertion is proven false by the
PoliticsOfPoker.com technology. A simple way to think about the limitations of anti-collusion systems
is to recognize that the vast majority of low or average skill poker players are not criminals. As
explained in more detail in the 'Internet Poker Anti-Collusion Systems Can Be Defeated Using
Undetectable Technology and Techniques' section, it is impossible for a computer to tell the difference
between an innocent poker player making a simple mistake and a colluding player making a deliberate
move. Furthermore, unlike the case of cheating, a 4-person money laundering team is unlikely to raise
suspicion among the other non-colluding players so the poker website will not be alerted to any
suspicious activity.

In a large scale money laundering system, one could use 50 or more money mule accounts and ensure
that the combinations of colluding accounts are varied so that hand histories for any given account
would make it all but impossible for a monitoring system to find anything suspicious. Simply put, if
skilled money launderers know that hand histories are recorded and have a basic understanding of how
a computer might search for suspicious patterns of play, they can introduce more than enough player
account combinations to hide from collusion detection systems. It is important to note that there would
be only 4 actual human players using the 50 money mule accounts in carefully selected combinations.
With this kind of counter-countermeasure in place, no system can detect a 4-person team without
producing so many false positives as to be useless.

Even if a software algorithm were devised that could detect subtle biases introduced by a 4-person team
playing behind 50 or more accounts, supercomputers would be required to analyze, within a practical
period of time, the millions of poker hands played every day. This computing hardware would likely be
so expensive that the internet poker business model will break down.

Copyright (c) 2010, PoliticsOfPoker.com