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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.

Why Use Internet Poker to Launder Money?

Forcing Law Enforcement to Consume Resources

Note: PoliticsOfPoker.com DOES NOT ADVOCATE the use of internet poker for any unlawful
purpose.

Supporters of Federal and state legislation intending to legalize internet poker in the United States
argue that regulation, other than prohibition, will limit cheating. They also cite the regulations put in
place by foreign governments such as those of the Isle of Man, the Alderney Islands, and Britain. Their
focus is usually on cheating. Little discussion is advanced regarding money laundering. This is
probably due to their assertion that other methods of money laundering are easier and thus not
attractive to drug traffickers and other criminals.

But if one considers the characteristics of a drug trafficking operation, the utility of internet poker
becomes obvious. First, money launderers do not require the complicity of the poker website operators.
This was one of the first constraints assumed by the developers of the PoliticsOfPoker.com technology
and techniques. Hiding from the website operators is far easier than a corrupt online sportsbook or
casino hiding from government regulators.

The objectives of any money launderer are to inject, layer, and extract money while avoiding handling
large amounts of paper cash. At the retail level, street dealers receive relatively small amounts of paper
money. The ideal money laundering system would enable the concentration of dollars into larger non-
cash pools while at the same time easing their movement across international borders – all outside the
conventional, global banking system. Now, let's assume that a poker money mule working for a drug
trafficking network is arrested and it is discovered that a large amount of money was transferred from a
poker account to the mule's bank account. All the mule will say is 'I won it playing poker.' If one were
to deliberately design an ideal money laundering system, it may well look like an internet poker
website.

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
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. And
eventually, assuming anti-collusion systems find suspicious activity, every player could be identified as
a money laundering suspect.

Copyright © 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.

The PoliticsOfPoker.com technology and techniques prove that there is no government or regulatory
authority anywhere on Earth that sufficiently regulates internet poker. They may write and pass
legislation but no existing laws can stop determined money launderers – certainly not those of the Isle
of Man, the Alderney Islands, or Britain.

The attached illustration shows a typical 9-seat internet poker table where the nine active players are
located in several countries. The scenario assumes that the player in San Diego, identified by the screen
name 'ThugTrader', is arrested for some crime and that a search of his home reveals evidence that
internet poker may be involved. Because the poker website operators follow every law and regulation,
investigators know every detail of the virtual table including the identities and hand histories of the four
past players. These are players who have left the table but were playing during the time the suspect
player was active.

Consider the following interrogation:

Investigator asks: ‘When was the last time you played poker?’
Suspect responds: ‘I’ve never played poker.’
Investigator asks: ‘Who are your counterparts at this poker table?’
Suspect responds: ‘I don’t know. I’ve never played poker.’

The suspect is telling the truth, leaving law enforcement no choice but to investigate all 8 of the other
players at the table plus, in this example, the 4 past players. How can this be? The suspect is a money
mule working for, but essentially separated from, the drug trafficker leadership. The money mule serves
only as a sacrifice to law enforcement – but one that has a legitimate identity, address, and bank
account. The poker games are played by higher level cartel operatives using custom built technology to
play the mule's poker account.

Consider the challenges faced by investigators when they approach their foreign counterparts. They
know that at least one of the 12 other players is involved but they don't know anything other than the
information provided by the poker website. It is possible that foreign law enforcement officials would
refuse to allow an investigation of their players due to the lack of evidence other than the fact that they
happen to have been at the same virtual table as the San Diego suspect. It gets worse. The drug cartel
could put procedures in place enabling the money mule network to reconfigure before the US-based
investigators find essential links to the cartel leadership.

Copyright © 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.

Investigations, especially those of an international nature, are expensive in terms of budget and
personnel. Leaders of drug trafficking networks are smart. They know how to hide and how to tax the
resources of their adversaries. Making internet poker legal and expanding the size of the player pool
will open a money laundering channel that will not go untapped for long. In fact, as the
PoliticsOfPoker.com technologies and techniques suggest, it is possible that large-scale money
laundering is occurring now.

PoliticsOfPoker.com agrees that internet poker should be regulated – it should be prohibited.

Copyright © 2010, PoliticsOfPoker.com

 Why Use Internet Poker to Launder Money?
Forcing Law Enforcement to Consume Resources

Player 9 Player 1
Gary, IN, USA Brighton, England

Player 8 Player 2
Manila, Lisbon,
Phillipines Portugal

Player 7
Bogota, Player 3
Colombia Vilnius,
Lithuania

Player 6
Ames, IA, Player 4
USA Lima, Peru

Player 5
Law Enforcement Suspect
Past Player 1 – Tijuana, Mexico San Diego, CA, USA

Past Player 2 – Copenhagen, Denmark

Past Player 3 – Chicago, IL, USA
Past Player 4 – Sydney, Australia
Copyright © 2010, PoliticsOfPoker.com