The Enforcement Directorate (ED) filed a prosecution complaint (chargesheet) against the online gaming platform WinZO, its directors, and subsidiaries on January 23, 2026.
The agency alleges that the company manipulated its gaming environment to dupe approximately 25 crore users—primarily from Tier-3 and Tier-4 cities—out of ₹734 crore through the systematic use of AI-driven bots and simulated profiles.
1. The “Bot Modus Operandi” (2022–2025)
The ED’s investigation, which involved analyzing codebases and internal communications, revealed a multi-stage strategy to defraud users:
- Pre-2023 (Hardcoded Bots): Until December 2023, the platform allegedly “embedded” games with AI-driven bots and algorithmic profiles while publicly promising a “bot-free” experience.
- Post-2024 (Simulated Play): From May 2024 to August 2025, the company reportedly switched to simulating the historical gameplay data of dormant or inactive users, pitting these “ghost profiles” against real players without their knowledge.
- Misleading Terminology: To hide these practices from internal audits and regulators, the company used deceptive labels like:
- EP (Engagement Play)
- PPP (Past Performance of Player)
- Persona
2. The “Lure and Lose” Strategy
The chargesheet describes a psychological trap designed to maximize user losses:
- Phase 1 (Trust Building): Users were initially attracted with small bonuses and pitted against “easy” bots to ensure early wins. Small withdrawals were allowed to create a false sense of security.
- Phase 2 (The Sting): Once users moved to higher “boot” amounts (stakes), the platform systematically deployed “Hard Bots”—profiles virtually impossible for human players to beat—leading to substantial financial losses.
- Phase 3 (The Lock): Even when users won at high stakes, the ED alleges WinZO used “restrictive withdrawal mechanisms” to block payouts, forcing them to continue playing until their funds were exhausted.
3. Financial Breakdown & Money Laundering
The scale of the alleged financial crimes spans several years and international borders:
| Key Financial Metric | Amount / Status |
| Total User Losses (to Bots) | ₹734 Crore |
| Proceeds of Crime (FY22–FY26) | ₹3,522 Crore |
| Withheld Legitimate Winnings | ₹47.66 Crore (Held post-Aug 2025 ban) |
| Assets Frozen by ED | ₹690 Crore (Bank balances, crypto, bonds) |
| Foreign Diversion | $55 Million (Siphoned to shell companies in USA/Singapore) |
4. Accused and Current Status
The chargesheet names the following as prime accused under the Prevention of Money Laundering Act (PMLA):
- Winzo Pvt. Ltd. (The Company)
- Paavan Nanda (Director – Currently in judicial custody)
- Saumya Singh Rathore (Director – Currently out on bail as of Dec 2025)
- Subsidiaries: Winzo US Inc. (USA), Winzo SG Pte. Ltd. (Singapore), and ZO Pvt. Ltd.
The agency noted that this “predatory” structure caused extreme mental and financial distress, particularly among users from economically weaker backgrounds, with some cases reportedly leading to self-harm.
Conclusion: The Death Knell for RMG?
This chargesheet follows the Union government’s August 22, 2025, ban on real-money gaming (RMG) apps. By documenting how AI was weaponized against consumers, the ED has provided the government with significant ammunition to defend the blanket ban in the Supreme Court, citing “national security” and “public interest” concerns over the industry’s unchecked growth.
