Jan 30, 2023
Once again, I find myself compelled by a thread on Poker Fraud Alert which links to another EZ Life Slot Jackpots video; this one concerning social media, “Group Pulls,” with a focus on those from TikTok.
The notion of, “Group Pulls,” is one that I had prior exposure to by way of some of the PA Skill Games Facebook Groups that I happened to be a part of anyway. When I notice these posts, I don’t really ‘Call the person out,’ per se, but I’ll usually say something like, “Oh, that’s a nice free roll you’ve got going on!” We’ll get into that a bit later.
The first thing that we want to do is explain exactly the sort of ‘Group Pulls,’ that EZ Life Slot Jackpots is talking about.
LEGITIMATE VS. QUESTIONABLE
The first thing that I note is, in EZ Life’s video, he categorically refers to these group pulls as, “Illegal,” and certainly, rightly points out that individuals in a few different jurisdictions are being investigated for their activities related to group pulls.
The one area where I take exception to EZ Life’s video is that he paints with a somewhat broad brush in categorically describing group pulls as, ‘Illegal.’
One thing that I see is that there are a number of laws that could be violated in conducting Group Pulls; I’m not saying there aren’t, but then, there are some situations in which I would think Group Pulls could be legal in certain contexts. For example:
- If the person conducting the Group Pulls is not getting an upfront cut or a cut of any winnings.
- If there is a clear financial chain of custody with documentation.
- If all participants are of the legal age to gamble in the jurisdiction in question.
- If the Group Pulls are not conducted by way of accepting money from a person in a state where it would be either illegal for that person to participate, or alternatively, illegal for the person in the state in which the gambling is being done to accept funds from the person in the state from which the funds are being sent.
Some examples of a Group Pull that seems legitimate to me, at least, the Golden Nugget casino was directly on board with it and helped out are some of those of NJ Slots Guy. I don’t know if all of the people participating were physically present, but I would assume it would go a long way to those group pulls being legit if they were.
Even if not all participants are physically present in a casino, I wouldn’t automatically assume that, because Group Pulls are happening, they are automatically illegal.
Another potential avenue for group pulls to be done legally, I would assume, is if someone takes donations from viewers/subscribers/followers and reserves a certain percentage of those donations to do Group Pulls, but does not explicitly state that is going to happen.
For comparison, I could say, “Hey, I’m going to play $500 in high-limit and everyone who comments on this article will get an equal piece of the winnings.” (I’m NOT doing that, by the way, but feel free to comment anyhow.) Of course, one key difference there is that I’m not taking anyone’s money.
Another example of a group-oriented thing that I believe to be lawful is my WoV NFL Picks Game, which you can find here. As you can see from the relevant rules:
- If you play, you are expected to pay the winner $25 if you do not win. There are no free dropouts. Even if you only play one week, you are agreeing to pay the winner if you lose. This is NOT a free contest.
- This is a social gambling game, so please check your jurisdictional laws to make sure that you do not participate unlawfully. It is not the responsibility of myself nor this website to ensure that you are participating lawfully.
- This game has no rake or house edge. In fact, I contribute funds to this game that make it +EV (all else equal) for everyone except myself. I do NOT directly collect any Entry Fees for this game, so participants are on the, "Honor System," to pay the winner.
- Mission146 is a resident of the Commonwealth of Pennsylvania who administers this game from same AND is offering this contest legally under social gambling statutes due to the fact that there is no, "Rake," "House Edge," or any other mechanism by which Mission146 stands to profit.
Basically, this is a social gambling game in which all participants are risking the same amount of money. I also contribute funds to the Prize Pool which, as with this season, sometimes exceed the total sum of the Entry Fees. There’s no House Edge and no mechanism by which I can profit. In years that I played (I didn’t in the 2022 Season) I theoretically could have profited by finishing in First Place, but it’s not so different from Fantasy Football and, with my prize contributions, everyone was playing at +EV even if I had, in fact, came in first place.
You’ll also note that I make it clear that I am both participating in, and administrating the contest lawfully and I state why. I also disclaim that I am not accountable to ensure that all participants are following the laws of their own states…in rare instances, some states have laws against participating in even social gambling games.
None of this is to pat myself on the back, by the way, or to promote NJ Slot Guy, (which this should not be seen as doing) but rather to say that there are situations where participation games or events are almost certainly legal. IOW, just because someone is holding some sort of group event or game does not automatically make the game illegal.
Even events that are questionable, such as with slot ‘Group Pulls,’ or those on PA Skill Games might not necessarily be illegal, depending on how they are being conducted. Without knowing the laws of every single state, I am a little more hesitant to categorically refer to a particular event as, “Illegal,” but I will say that there are many elements that could make a game, at least, very questionable.
1.) Percentage of Winnings
- The first aspect that might make something like this questionable is if the person conducting it is getting a percentage of the winnings. Even if they are not charging an upfront fee, or percentage, it still amounts to a total free roll for the person conducting the event. That’s to say, if the Group Pulls lose, then the person is out nothing; if they win, then the person conducting the event profits.
- Legalities aside, if all of this is clearly stated (and other laws are, arguably, being followed) then I don’t necessarily have a problem with this by itself. Is an event such as this something I would do? No. At the same time, the Libertarian in me says, “Well, if the people know that a percentage will be taken out of any winnings and are fine with that, then I really don’t see what moral objection I could have to it.”
2.) Upfront Fee & Percentage of Winnings
- The events that seem common in the EZ Life Slot Jackpots video would be TikTokers who not only will take a percentage of winnings, but also, charge a percentage of any monies contributed to the Group Pulls and/or charge an additional flat fee in order to participate.
- Again, I would hesitate to flatly declare such a thing to be illegal without knowing the laws for the states of all participants. While there’s a reasonably high probability that this violates one law, or another, I would not absolutely declare it to be so.
- Still, such a situation is more than a freeroll; it’s a guaranteed money maker for the person hosting and broadcasting the event. If there are winnings, then the person gets their percentage; if the group’s bankroll is wiped out, then the person still got their percentage (or flat fee) on all of the deposits.
3.) The Age of Participants
- This is where I think some of these folks could be buying a one way plane ticket to Big Trouble Island. If any of these people are not strictly verifying the ages of all participants, then they are gambling, by proxy, on behalf of people who are not legally old enough to gamble.
- I’m sure that they would argue something like, “Well, the minor is not the one doing the gambling,” and I would counter, “Yes, they are, just not directly.” I see it as no different than taking the money of a minor, going to the liquor store, buying a bottle, giving it to the minor and saying, “Well, the kid didn’t buy it.” I mean, you can’t even give liquor to a minor free of charge to them!
- I don’t think having some stated policy that says, “All participants must be 21 years old,” and just taking their word for it is going to get the host out of trouble, either. If you host a party with a rule that says individuals must be 21 to drink, but a minor consumes alcohol at your party because you did not actually verify the person’s age, then you will be legally accountable.
OTHER ANGLES TO SHOOT
We’ve already covered the basic fact that these sorts of Group Pulls, one way or another, are essentially free rolls for the person hosting the event. Personally, legal or not, I would say that rises to the level of being an angle. That’s especially true with those who take a percentage of deposits, or charge an Entry Fee, because they are going to profit something regardless of what happens.
Another potential angle that I see is most of these hosts state that taxes, if some sort of taxable jackpot is hit, will be paid at the time it is hit.
On the surface, that makes total sense. The individual who hits the taxable has to sign a W2-G, so obviously, they would not want to be held accountable to pay taxes (out of pocket) on money that does not fully, or perhaps does not at all, go to them.
However, as I have stated in articles that, directly or indirectly, have to do with taxation on gambling winnings, individuals can write off any such winnings to the extent of their losses, up to 100%. Therefore, one angle that can be shot is, “Paying,” the taxes that you are just going to write-off and get a refund on anyway. Should that happen, then the host is going to end up profiting even over and above any directly stated fees.
Another possible angle is that the person states that Federal Taxes will be taken out, but simply, does not actually have the casino take out the taxes. I should assume that most livestreamers aren’t going to want to have identifying information (address/birthday/social) appear on the livestream, so my inclination is to think there is a pause and the viewers often don’t actually see the taxable being dealt with.
One angle I have seen, this one perhaps unique to PA Skill Games, is that the viewers’ money is sometimes treated separately. In other words, the host will declare when they are playing x, y or z person’s money, but all of the supposed ‘Group Pull,’ funds are still treated separately.
The obvious advantage to that, for the host, is that it gives the host multiple opportunities to profit on what is the same total amount of money.
For example, if they say that what they are going to do is, “Double or Nothing,” with total funds of $1,000, then they would need to hit $2,000 to cash out if all monies were treated as the same pool of funds. However, if instead they had ten different viewers each playing $100 individually, then they would get a piece of the profits anytime the $100 is doubled to $200, or more. Obviously, such a situation greatly increases the probability that there will be some amount in winnings for the host to get a piece of.
Fortunately, these PA Skill Games Group Pulls either seemed to not really take off, (and the would-be hosts gave up) or alternatively, the Admins of the various groups decided to do something about them. One way or another, I haven’t seen as many posts of this nature as I used to.
Of course, I usually called this out when I saw it by making comments such as, “Nice free roll,” (where the would-be host would usually make the mistake of pretending not to know what I meant and I would really dress them down) but I didn’t go as far as to report it to the Group Admins.
I should also say that I wasn’t the only person making comments along these lines as many people would chime in and ask, “Why would I want you to gamble my money when I can just play with my own money?” The more intelligent ones wouldn’t get defensive when it came to these sorts of questions or, if I saw it, I would go on there and very clearly describe exactly what angle I knew they were shooting.
THE POISON THAT IS SOCIAL MEDIA
The fact of the matter is that Social Media is poison and, in the age of influencers and going viral, people are simply looking for quick ways to cash in. In all honesty, I don’t even think that I would necessarily accuse every single person of doing this in a malicious way.
Certainly, some of them know exactly what they are doing and are trying to shoot angles and get themselves some free rolls, but I don’t think that’s true of everyone. While it may only apply to a minority, I think the thought process for some people is, “Hey, I’m going to facilitate this thing where we can all play together…sharing the same wins and losses…so why shouldn’t I get a small percentage for putting the whole thing together?”
Of course, I see smaller angles being shot all the time.
One angle that I see a lot on Facebook, and for some reason, PlaySugarhouse and BetRivers seem to be the big casinos where people try to do this is that they offer to share their referral link (they get casino credit for doing so) and then explain the promotion that people will get if they sign up using their link.
The problem, of course, is that it’s the same exact new player promotion that the mark would get even if they DID NOT sign up using the other person’s link! That’s right! Many of them go on and make a post implying that is a promotion that other new players will get IF they sign up using the poster’s link, but really, they are entitled to the new player promotion whether or not they are referred.
Generally speaking, I will leave posts like that alone and only go after the person (in comments) if they are spamming the Group with these posts on a regular basis. On the one hand, yes, they are trying to get free casino credits; on the other hand, they are also making good promotions known to others and signing up using the referral link doesn’t deprive the mark of something they would otherwise be getting. I wouldn’t say that it’s, “Harmless,” but there’s certainly very little harm being done, if any.
GROUP MONEY ON ONLINE CASINOS
One other thing that I have noticed is that people will sometimes solicit donations to play group funds on online casinos…and, my word, are there a ton of problems with that!
The first problem is that playing with other peoples’ money would unambiguously be against the Terms and Conditions for any online casino I have ever heard of! What’s going to happen if the casino itself sees this sort of play taking place? These livestreams (especially the ones that get left up as videos) are handing the online casinos evidence that you are directly violating their Terms & Conditions.
Of course, that leads to the next problem: What if the host of the group event does not get paid by the online casinos? Given that they are violating the Terms and Conditions of the online casino, I would say that there is a very strong possibility that they will not be paid. What is the procedure for that? Is the host paying everyone their cut as soon as the event is over, or is your getting paid conditional on them being paid?
Everything that I said in the, “Legitimate vs. Questionable,” section also applies here.
Another angle is that the person could collect all of the funds from the participants and play with that money prior to going live and here is how that would be done.
1.) If Profit
- If there is a profit, then the person could request a withdrawal for such an amount in excess of the initial deposit. They can leave the deposit on there and, even if the withdrawal request has not been paid out yet, those funds for which the person has requested a withdrawal will not be displayed in the balance.
- At that point, the person can then go live and play legitimately. If they lose, then they just lose, but will have whatever amount they have already requested a withdrawal for. In the event the person wins, then the person will request a withdrawal for the new amount, get their percentage of that, and also get everything that was won before they go live.
2.) If Loss
- In the event the person loses, then they can have recorded that session with screen capture and simply replay it, while offering commentary, as if it is being done live.
Granted, some online casinos have a clock that appears when playing all games, but I don’t think all of them do. Beyond that, the person could also say they must conceal the clock on their screen on the pretext of hiding some other information.
3.) Not Play at All
When it comes to online casinos, this would take some time and a fair amount of technical know-how, but the person could conceivably create a video of online play that simply did not actually exist. I can’t claim that has ever happened, but if it could be done, then the person would end up simply keeping all of the funds because they could do a video that shows losing even though they never played at all.
TOTAL LACK OF RECOURSE
The biggest problem that viewers participating in these Group Pulls might have is a total lack of recourse if they do feel they were ripped off in some way, or alternatively, straight up got no paid. This seems unlikely, at first blush, because the person to get stiffed would obviously complain all over the social media outlet that the host uses, but if the host is desperate enough, they might decide to just, “Burn it to the ground,” take whatever money they can get, then disappear from social media entirely.
HOW TO PROTECT YOURSELF
You can protect yourself by simply not participating in group pulls.
THE LIBERTARIAN IN ME…
I want to offer an apology should anyone find themselves offended that I am not taking quite the hardline stance against this sort of, “Group Pull,” activity that EZ Life Slot Jackpots is.
The first reason that I can offer for that is simply that I am not as convinced that this sort of activity is categorically illegal as he is. He makes a statement that says, “Sending money across state lines, in fact, sending money to anyone, to gamble, is illegal.”
Immediately, I must say that I don’t believe that statement is automatically true. State lines can blur the issue and, I would say, make it significantly more likely that an illegal transaction has taken place, but even then, I wouldn’t categorically declare that. Here’s an example:
***Let’s look at the most vanilla transaction we could think of. Person A is near a casino and is preparing to place a sports bet at a sportsbook. Person B calls Person A and Person A tells Person B what he is doing. Person B is of legal gambling age, is not self-excluded from casinos in the state and is also in the same state as Person A. Person B asks Person A to put $100 on the Buccaneers to win whilst Person A is at the casino. Person A asks Person B if he would be cool with sending Person A the $100 on Paypal as both have a habit of sometimes forgetting about these things. Person B does; Person A makes the bet on Person B’s behalf.***
Again, this almost doesn’t share any elements in common with Group Slot Pulls, the sending and receiving of money aside, but that’s why I avoid making blanket statements like the ones I quoted from EZ Life. The event that I describe might be illegal, but I think that would very much depend on the state in question.
And, on the off-chance that the event described in my example would be illegal, I would say it certainly shouldn’t be.
EZ Life also suggests that the event of sending money to someone else to gamble for you violates the Federal WIRE Act as well as vague, “Anti Money Laundering laws.”
Again, I think EZ Life is describing laws that could be violated in some of these instances, and are almost certainly violated sometimes, but I don’t believe that the underlying act of one person sending another money to place a bet automatically violates these laws.
For one thing, in order for anything to ever be money laundering, the result has to be moving dirty money around or moving money in such a way as to conceal the chain of the funds. That’s why I said above that keeping a clear accounting of what money belongs to who would be relevant because, while you might have something else, you wouldn’t have money laundering.
Going back to my sports bet example, the $100 wasn’t laundered any more than Person A giving Person B a $20 and asking Person B to grab him a pack of smokes since he’s going to the grocery store anyway and to bring him the change. Just because an unclear chain of financial custody might be the case sometimes, perhaps even usually, does not mean that the underlying act is automatically illegal—which is why I don’t like this sort of imprecise language being thrown around when discussing legalities.
Person A gets the $100 on PayPal; Person A bets the $100 on behalf of Person B; Person A provides Person B with the ticket, or the original wager and winnings if Person A also cashes the ticket, (we will assume a non-taxable event) so nobody in that scenario is trying to, “Wash,” any money or trying to conceal the chain of anything.
The main problem that I have with this sort of language is that it is precisely why some extremely uninformed people think things such as hole-carding, edge sorting or even card counting, are illegal. People throw words like, “Money Laundering,” “WIRE Act,” and, “Illegal,” around all willy-nilly, and perhaps out of an overabundance of caution, other people automatically believe that to be true because they heard someone else say it.
It’s important to note that the WIRE Act is extremely complicated and even some arms of the Federal Government have disagreed with other arms as to what conduct is made illegal. Here’s a quote from a ruling suggesting that the WIRE Act would only apply to sports betting:
The district court next articulated several reasons why the Plaintiffs may not rely on federal mail or wire fraud as predicates.22 Of these reasons, two are particularly compelling. First, Thompson and Bradley cannot show that the Defendants made a false or fraudulent misrepresentation.23 Because the Wire Act does not prohibit non-sports internet gambling, any debts incurred in connection with such gambling are not illegal. Hence, the Defendants could not have fraudulently represented the Plaintiffs' related debt as legal because it was, in fact, legal. We agree that “the allegations that the issuing banks represented the credit charges as legal debts is not a scheme to defraud.” 24 Second, Thompson and Bradley fail to allege that they relied upon the Defendants' representations in deciding to gamble.25
Basically, the case dealt with individuals who used their credit cards (MasterCard) to fund deposits into an online casino. These individuals lost, but attempted to sue MasterCard on the grounds that they should not have to pay these chargers as MasterCard violated the WIRE Act in allowing the money to be deposited into the online casinos.
The original case was dismissed and the dismissal was affirmed. It’s worth noting that the Unlawful Internet Gambling Enforcement Act came into being after this event, but even if it had already existed, it would only prevent MasterCard from knowingly engaging in financial transactions with an offshore online casino.
I want to make it clear that I can think of any number of laws that these Group Pulls might be in violation of, but to suggest an automatic violation of the WIRE Act? No; just, no.
Another aspect to note in this ruling above is that sports betting isn’t even prohibited anymore because the Professional and Amateur Sports Protection Act (PASPA) was overruled by the Supreme Court in the intervening years. With that, while there are any number of possible in-state laws that could be violated, or perhaps even Federal laws, (when it comes to interstate money exchanges) I would think it would come down to more specific circumstances and would not just categorically and automatically be an illegal transaction at the Federal level.
I also want to make it clear that I am not saying this sort of activity is NOT illegal; I am simply saying that I don’t believe that it’s automatically illegal and its legality is largely going to depend on the specific circumstances involved. I definitely don’t believe it’s a violation of the WIRE Act, at least not necessarily and I certainly don’t think it could ever qualify as money laundering as long as clear records of what belongs to who are being kept.
Again, for money laundering, you have to be disguising the source of the money. In the case of these group pulls, not only are you NOT disguising the source of the funds, but more than that, you are actually creating a record of where the original funds came from!
With all of that out of the way, I do want to offer some opinions on these Group Pulls. Again, these opinions are going to be colored by my Libertarian leanings and I respect and encourage anyone who would disagree with any of these to do so in the comments! I’m always in favor of discussion and sharing of ideas/opinions as long as we can do it in a respectful way.
To the Participants
My advice is not to participate.
I have already shared my opinion of the many ways you could be potentially defrauded by one of this group pull hosts, such as the results not being correctly represented or straight up being no-paid.
For those reasons, my advice is not to participate in these sort of group pulls.
I would also advise individuals not to participate because the notion of giving someone a free roll with your money strikes me as pointless. Granted, you might not think it’s a waste of money, or you might feel like your participation in the group event is worth the percentage of your winnings (if any) that will come out, but effectively, you’re only adding to the edge against you on the game.
I simply don’t see the benefits of participating in a (paid) group pull that effectively has juice added to it. In my opinion, the worst part is that you’re allowing someone to free roll on your money. If they take money right off the top, then you’re effectively paying them to free roll on your money.
That Having Been Said
The Libertarian in me must admit not having a problem with this as long as no laws are flagrantly being broken, at least, no laws that actually ‘matter.’
For that reason, if the following are true:
- The group pull is legitimate and is being conducted honestly.
- There is a proper tracking of the financials and what belongs to whom.
- All participants are consenting adults.
- No participants are self-excluded, or otherwise excluded, from any casinos.
Then, I’d have trouble saying I really have a problem with it.
Look, if you’re willing to pay someone a $50 fee upfront (or whatever amount) and then send them $550 with them to play $500 of that and keep 10% of the profits, or total, if any…as long as it is clearly explained and you understand and agree to the terms, then it’s not for me to tell you what to do with your money.
Do I think it’s dumb? Absolutely.
In conclusion, my position on these Group Pulls is very situational and would vary depending on the specific circumstances of each event.
I disagree with EZ Life Slot Jackpots’ apparent conclusion that these sorts of Group Pulls are categorically illegal as I could think of a great many instances in which they would be legally perfectly fine.
I wouldn’t accuse EZ Life of bias, but one aspect of this that doesn’t escape my attention is the fact that a big percentage of what EZ Life does is film slot play, so if casinos were to all categorically decide (as a result of group pulls and such) that slot play is no longer to be filmed under ANY conditions, then I could see where that would be very bad for EZ Life. Again, that’s not meant to cast aspersions, but one can’t help but wonder why else he would take such a hard ass stance on this sort of activity being categorically illegal—which I don’t even think is always true.
I would say that they could be illegal in many instances, not because of money laundering or the Federal Wire Act necessarily, but because there are a plethora of potential state laws that could be potentially violated. However, the statement that it’s automatically illegal to send someone money for the purpose of gambling…no…that statement is abjectly ridiculous if meant to apply to the entire country, but I will gladly admit to being wrong if EZ Life, or anyone, can demonstrate to me that there is a Federal law stating that any and all electronic exchanging of money for the purpose of gambling is illegal.
However, I think Group Pulls are an extremely dumb way to spend money.