The Enforcement Directorate has intensified its investigation into online gaming platform WinZO by arresting its co-founders, Saumya Singh Rathore and Pavaan Nanda, in connection with a money laundering probe sparked by multiple cheating and financial loss complaints from users across the country. The development follows extensive searches conducted at the company’s offices and residential premises on November 18, 2025, under the Prevention of Money Laundering Act, and marks a significant moment in India’s tightening regulatory scrutiny of real-money gaming platforms.
ED focuses on cheating complaints, hidden gameplay algorithm and restrictions that caused user losses
The ED’s case draws from several FIRs filed nationwide alleging that WinZO engaged in deceptive practices, misused personal data, blocked user accounts without justification, and created situations where players suffered financial losses. WinZO, formerly known as Ticktok Skill Games Private Limited, entered the online gaming market in 2016 and became known for its “WinZO” app, which offered real-money games such as rummy, solitaire, ludo, poker, and chess. These games had widespread appeal, particularly in small towns and rural regions, contributing to the company’s claim of more than 250 million registered users.
The company has asserted that it stopped offering real-money games in India after the Promotion and Regulation of Online Gaming Act, 2025, came into force. However, the ED said that its investigation revealed multiple discrepancies between public claims and the company’s operational behaviour. One of the most serious findings was the discovery of a concealed algorithm known internally as PPP, or past performance of player, which was allegedly used in real-money games to influence outcomes without informing users.
According to investigators, the PPP system matched human players against automated gameplay simulations built from historical behaviour of earlier users. These simulated profiles, the ED said, were repeatedly deployed without the knowledge or consent of the users whose data had been used to create them. In effect, players were unknowingly competing against algorithm-generated opponents that may have had statistical advantages. The agency believes the system allowed the company to generate more than ₹177 crore in revenue over a 14-month period while causing financial losses to genuine participants.
One of the examples cited involved a user who had played only a single game in January 2025. ED officials found that his profile was used to generate automated gameplay for 32 games in March of the same year without his awareness. This discovery, the agency said, was symptomatic of a much larger pattern in which player data was repurposed without transparency.
Financial design choices within the app further compounded user losses. The ED’s findings indicate that WinZO allowed users to deposit money into their in-app wallets without any restrictions, but imposed strict conditions on withdrawals. Players were permitted to withdraw only their “winnings,” not the money they had originally deposited. This structure, combined with daily withdrawal limits determined by loyalty tiers, allegedly created a scenario where users were compelled to continue playing if they hoped to access their money. The maximum daily withdrawal limit was around ₹99,000, although most users were confined to far lower thresholds.
Investigators argued that this system made users vulnerable to losses, especially when paired with the PPP algorithm, which they claim skewed outcomes. In addition, many users found their wallets blocked arbitrarily. The escrow account operated by WinZO reportedly contained around ₹43 crore tagged as “payable to users,” which the ED described as evidence of widespread withholding of legitimate funds owed to players.
The allegations gained further weight when ED teams uncovered operational practices that suggested systemic concealment. During searches, officials found that the company maintained extensive logs and internal notes related to algorithm tuning, data modelling, and outcome balancing. These internal documents, according to investigators, hinted that the company was aware that certain gameplay mechanics could negatively impact users but continued to use them for commercial gain.
The ED also noted that several complaints involved misuse of PAN details. Some users alleged that their PAN information, required for verification under gaming regulations, had been used in ways they did not authorise. Investigators are examining whether PAN misuse contributed to tax discrepancies or KYC-linked manipulation within the platform.
These findings prompted the ED to act swiftly, arguing that the company’s operational model created an environment where users could be misled about their odds of success, while their personal information and financial inputs were mishandled. This formed the basis for invoking the money laundering provisions.
Offshore entities, foreign bank accounts and user database transfer agreements intensify ED’s scrutiny
The ED’s investigation expanded significantly after uncovering details about WinZO’s ownership structure, offshore subsidiaries, and foreign fund movements. WinZO operates three subsidiaries, two of which are located overseas—one in the United States and one in Singapore. Although these companies are registered abroad, ED officials found that day-to-day control, operational decisions, and even foreign bank account management were directed from India.
Investigators have alleged that the company routed funds to its US subsidiary by gradually diluting shares over time. This process reportedly resulted in the movement of substantial sums of money to foreign accounts. As of November 22, foreign bank accounts associated with WinZO’s US entity held approximately USD 55 million, equivalent to around ₹489.9 crore. The ED is currently examining whether these funds represent legitimate investment activity or whether they are linked to proceeds generated from practices under scrutiny within India.
Officials highlighted that one of the most concerning discoveries was an agreement to transfer intellectual property and a massive user database—reportedly containing around 250 million customer records, along with KYC documentation—to the company’s US unit. This agreement was prepared after India enacted a ban on certain categories of real-money games. Investigators believe that shifting this data offshore could obstruct oversight by Indian regulators and complicate future enforcement actions.
The ED is investigating whether the proposed transfer was designed to move critical business assets out of India before regulatory tightening. If executed, this shift would place sensitive user information under foreign jurisdiction, prompting significant questions about data privacy and compliance with Indian data protection rules.
WinZO’s corporate structure and its multiple foreign subsidiaries raised red flags for investigators, who are now working to determine whether funds moved abroad were disguised as legitimate business investments. The company’s share dilution strategy is under scrutiny, with the agency checking whether inflated valuations or related-party transactions were used to justify moving money into overseas accounts.
Investigators also found evidence of operational instructions being issued from India to teams managing foreign accounts, which could indicate that the offshore units were not functioning independently, despite being registered abroad. This raises questions about whether the overseas operations existed primarily to facilitate financial transfers or reduce regulatory visibility.
Meanwhile, ED’s analysis of user complaints shows a pattern of grievances concentrated around withdrawal issues, blocked accounts, and unexpectedly large losses during gameplay. Many users reported that their attempts to retrieve wallet funds were met with repeated delays, verification demands, and sudden freezes. These problems stretched over months and often resulted in players abandoning their funds altogether.
The scale of user grievances has led the ED to consider whether the company employed psychological nudges, reward mechanisms, or manipulative app design strategies that pressured players to continue spending. Although the agency has not presented conclusions on this aspect, it is studying behavioural data models seized during searches.
The ED’s findings have caused concern across India’s rapidly growing digital gaming industry, which has been under regulatory pressure since the enactment of the Promotion and Regulation of Online Gaming Act, 2025. WinZO’s arrest-linked developments may set precedents for how real-money gaming platforms will be monitored in the future, particularly concerning algorithm transparency, user data handling, and withdrawal policies.
For now, officials maintain that the investigation is ongoing and that more arrests or asset seizures may follow. They believe that the company’s internal systems, offshore transfers, and gameplay algorithms formed a network of practices that generated significant revenue through methods that may not have been disclosed to users or regulators.
