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Guarantee Platform & Analysis of Black and Gray Market Operations: Including On-Chain Tracking, Legal Interpretation, and Response Methods

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PANews
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4 hours ago
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Author: Chain Analysis Crypto Lab

Huiwang to Haowang: The "Shell Game" of Overseas Guarantee Platforms and the Industry Landscape

(1) Nature of Guarantee Platforms: The International Version of "Xianyu"

In the Web3 ecosystem, a guarantee is originally a mechanism providing trust endorsement for legitimate transactions—just like a third-party guarantee when shopping on Xianyu, where the buyer deposits funds with the platform after payment, and the seller receives the payment only after confirming receipt. However, these so-called "guarantee platforms" overseas have turned this mechanism into a "veil" for illegal and gray activities.

The commonality of these platforms is that they essentially lack formal financial licenses, operate relying on TG (commonly known as Telegram), and use USDT (stablecoins) as their main trading medium. Their core function is to provide fund custody and arbitration for illegal transactions such as telecom fraud, money laundering, and human trafficking, allowing criminal acts to be completed smoothly under the disguise of "guarantee." To put it simply, legitimate guarantees protect lawful transactions, while these platforms protect criminal transactions.

(2) Huiwang/Haowang Guarantee: The Sanctioned "Super Hub of Black Industry"

When discussing guarantee platforms, we cannot avoid Huiwang Guarantee, a platform referred to in the industry as the "Alipay of the black industry." Its development trajectory is essentially a history of the evolution of black and gray activities:

  • Circa 2020: Cambodia's Huiwang Group launched Huiwang Guarantee, rapidly rising by relying on the geographical advantages of Southeast Asia's telecom fraud parks.
  • 2022: Due to involvement in large-scale telecom fraud and money laundering, it was included in the sanctions list by the U.S. Department of the Treasury, assets were frozen, and large amounts of user funds became inaccessible.
  • 2023: Rebranded as "Haowang Guarantee," continuing operations in TG groups while attempting to evade regulatory crackdowns.
  • From 2024 onwards: Despite multiple changes in servers and operational teams, it remains under close monitoring by regulatory bodies globally, with frequent issues of bank runs and withdrawal difficulties.

As the industry's "leading" player, Haowang Guarantee's business scale is astonishing: the cumulative transaction volume exceeds $27 billion, covering black industry practitioners in over 100 countries and regions, with a usage rate exceeding 80% in the Southeast Asia telecom fraud park.

Haowang Guarantee Platform's Operational Model:

  • Sellers (fraud gangs/individual information traffickers) post "products" on the platform, which could be tens of thousands of pieces of personal information, a set of bank card skimming tools, or even "channel resources" for human trafficking;
  • Buyers (downstream fraudsters/illegal traders) see this and transfer USDT to the platform's designated wallet;
  • After the seller dispatches the goods, the buyer confirms receipt (i.e., confirms that the information is usable, and the tools are functioning);
  • After deducting commission, the platform transfers the remaining USDT to the seller;
  • If disputes arise, the platform acts as an "arbitrator," but the arbitration standards lean towards black industry logic, such as the determination of whether "the information is usable" being based on whether the buyer successfully conducts a fraud.

The most frightening aspect is its "anonymity": no real-name certification is needed; anyone with a TG account can register, and the entire fund flow uses USDT, completely free from regulation.

The Chain Analysis technical team has assisted law enforcement in tracking the flow of funds from a certain telecom fraud case, one amounting to 500,000 yuan from domestic victims, which was withdrawn by card farmers, converted to USDT by U-traders, and completed transactions through Haowang Guarantee, ultimately flowing to overseas fraud gangs. The entire process took only 48 hours, with the fund trails fragmented.

(3) A Visual Understanding: Four Major Categories of Overseas Guarantee Platforms

As an important hub in the black and gray industrial network, guarantee platforms have developed rapidly in recent years, with both user and fund scale growing exponentially.

According to on-chain data, within the past three years, the three giants Huiwang Guarantee, Tudou Guarantee, and Xincoin Guarantee have processed over $78 billion in USDT transactions. This amount surpasses the GDP of many small to medium-sized countries.

In addition to the three major guarantee platforms mentioned above, there are various guarantee platforms overseas with clear divisions of labor covering different black industry scenarios. Below is a detailed comparison of the four major types of platforms:

[Note]: The above data is synthesized from case materials from the task force/on-chain data tracking and industry research. The business volume represents cumulative transaction scale, and risk levels are comprehensively assessed based on the intensity of regulatory crackdowns/stealth/impact scope.

The commonalities of these platforms are also very obvious:

❶ Trading media rely on USDT (USDT is pegged 1:1 to the U.S. dollar, with stable prices and rapid cross-chain circulation, enabling quick splitting of large amounts of funds)

❷ Avoiding formal channels, using TG as an operational vehicle (TG’s encrypted communications and group functions make it easier to hide operational traces)

❸ No substantial risk control, as long as commissions can be paid, any illegal transaction can be guaranteed

Black and Gray Industry VS Guarantee Platforms: How Ordinary People Come into Contact with Them

(1) Guarantee Platforms VS Black and Gray Industry: Resolving Trust Crises Among Criminals

Practitioners in the black and gray industries are essentially "mutually suspicious scammers."

Why do we say this? Scammers fear the personal information they purchase may be fake, while information traffickers fear they won’t receive payment after delivering the goods; money laundering teams fear that connected U-traders will "eat black," and U-traders fear being silenced after laundering money. This innate lack of trust provides living space for guarantee platforms. In simpler terms, the existence of guarantee platforms allows scammers to trade without worry.

Below is a real case from our technical team's assistance in an investigation:

A certain telecom fraud gang wanted to purchase "four essentials" (bank card/ID copy/mobile card/U-shield) for money laundering, with the seller being a domestic "card farmer" intermediary. The two parties did not know each other, both wary of the other possibly being an undercover agent, yet fearful of being scammed—the buyer worried about paying for unusable essentials, and the seller feared giving away essentials without receiving money.

At this moment, Haowang Guarantee became their "trust bridge."

The entire process ensured that both sides completed the transaction smoothly while providing anonymity protection, allowing the criminal act to close the loop. Without such a platform, many black market transactions would be impossible—this is the fundamental reason why guarantee platforms are irreplaceable in the black and gray industrial ecosystem.

(2) Guarantee Platforms VS Ordinary People: Beware of "Quick Money" Traps!

That said, many people feel that the black and gray industry is far removed from themselves. However, these guarantee platforms are infiltrating our daily lives through various channels, especially targeting those who want to "earn quick money" as prime prey:

  • Social platform lead generation: On certain social platforms like Douyin or Xiaohongshu, using keywords like "virtual currency flipping," "USDT exchange profit," or "zero-threshold commission tasks" to attract users, then guiding them to add WeChat or QQ, and subsequently transferring to TG groups.
  • Introductions from acquaintances: Friends and relatives recommend that "there is a business for earning pocket money, just help transfer some money, and you can earn a commission." Many relax their guard under the endorsement of acquaintances and eventually become tools for crime.
  • Dark web redirection: During regular internet surfing, one may "accidentally" see ads for these platforms pop up and, upon clicking, get redirected to TG groups. These overseas guarantee platforms may also involve more serious crimes such as drug trafficking, weapon sales, etc.

(3) The Role of Guarantee Platforms: Three Core Roles in the Black and Gray Industry

If black and gray industries form a supply chain, guarantee platforms serve as the “core hub,” playing three key roles:

  • Funds security "guardians" providing custody for illegal transactions, resolving trust issues among black industry practitioners, allowing for "safer" fund flows.
  • Criminal acts "legitimization" disguisers disguise illegal transactions as normal commercial activities, lowering psychological defenses for participants and increasing the difficulty of regulatory crackdowns.
  • Funds trail "fragmenters" sever the connection between illegal funds and their sources through USDT transfers, cross-chain movement, and multi-address splitting, making traceability difficult.

Our technical team once tracked the on-chain data of a guarantee platform, discovering that one core wallet address had transactions with over 1,200 suspected black industry addresses within six months, involving funds exceeding $800 million, which ultimately flowed to overseas exchanges, anonymous wallets, and other guarantee platforms, forming a complex funds network, greatly increasing tracing difficulties.

Exclusive Chain Analysis: The Operational Model of "Laicai Guarantee" Black Industry Empire

As a Web3 technology security company, we have assisted task forces in tracking and analyzing multiple illegal guarantee platforms, among which "Laicai Guarantee" (to protect case information, the original platform name and data have been desensitized) represents a highly typical operational model. Its complexity and concealment are exemplary of black market guarantee platforms—essentially a "textbook."

(1) Laicai Guarantee's Two Core Businesses: From Guarantee to Money Laundering

Firstly, from our tracking and analysis of the data, Laicai Guarantee is not a singular guarantee platform but has built a black industry ecological empire centered around guarantees, covering money laundering, system renting, and customer maintenance—its four main businesses are interlinked in a closed loop.

Core Guarantee Business

The guarantee business is the foundational and most core operation for the Laicai Guarantee platform, providing fund custody and arbitration for black market transactions. Its process is similar to that of Haowang Guarantee but more targeted—mainly serving the connections between "money laundering teams" and "fraud gangs." For instance, if a fraud gang needs to recruit money launderers, both parties deposit USDT on the platform and agree on money laundering rules, then withdraw their deposits through the platform afterward, with the platform taking an 8% commission.

From on-chain data, Laicai Guarantee has three core virtual currency addresses that correspond to the deposit, reserve fund, and withdrawal functions:

Deposit Address (TKxxxx1): From May 2024 to February 2026, it accumulated inflows of 96,561,800 USDT, all from suspected black industry addresses, mainly used to collect deposits from both trading parties;

Reserve Fund Address (THxxxx2): From July 2025 to February 2026, it accumulated inflows of 12 million USDT, all from the deposit address, mainly used to showcase "platform strength" to black industry practitioners to attract more users;

Withdrawal Address (TPxxxx3): From March 2025 to February 2026, it saw inflows of 937 million USDT, mainly from the platform's money laundering business address, used for returning deposits after transactions, showing a characteristic of "large input and small output," with more small amounts flowing out, perfectly aligning with the funds flow of deposit returns.

Money Laundering Business

The platform independently developed a money laundering APP, where code farmers (money laundering personnel) must pay a deposit (minimum 5,000 yuan or equivalent USDT) in advance to participate in money laundering order grabs. After receiving illegal funds, code farmers convert them to USDT via exchanges or currency traders and send them back to the platform. After the platform takes its commission, the remaining funds are transferred to overseas bets.

We tracked three core payment addresses of the platform, with accumulated transaction volumes reaching 933 million USDT:

Unique Payment Address (TQxxxx4): From February 2025 to February 2026, it processed 715 million USDT, primarily responsible for returning deposits and making transfers to overseas betting platforms;

Unique Collection Address (TLxxxx5): From January 2025 to February 2026, it processed 674 million USDT, with funds mainly coming from exchanges and currency trader addresses, serving as the main receiving address for user transfers.

(2) Laicai Guarantee's Technical Concealment Methods: Vigorously Evading Regulatory Tracking

As a technology security company, we conducted an in-depth analysis of Laicai Guarantee's technical architecture and found that to evade tracking, it employs a series of professional concealment methods, which are common practices among many illegal guarantee platforms:

  • Multi-chain parallel + cross-chain transfer: Mainly using the TRX network for transactions, while also supporting transfers across Ethereum, Binance Smart Chain, and other multi-chain platforms, frequently switching funds between different chains to sever transaction trails;
  • Multi-signature addresses + anonymous wallets: Core addresses employ multi-signature technology, requiring multiple private keys for authorization to transfer funds, with all funds ultimately directed to decentralized anonymous wallets that cannot be linked to real identities;
  • Distributed server deployment: Operational servers are located in Cambodia, Myanmar, Russia, and various other countries, using VPNs and proxy machines to hide their real IPs. Even if a certain country's server is shut down, other servers can continue to operate;
  • Transactional fragmentation: Large sums of money are split into multiple small transactions, each usually under 1,000 USDT, with irregular transfer time intervals to avoid triggering monitoring rules on the chain;
  • Regular address changes: Core business addresses are changed every 3-6 months, and old addresses are no longer used, making it difficult to sustain tracing efforts.

Legal Red Lines: Dual Risks for Guarantee Platform Operators and Participants

Having discussed technical aspects, we should now turn to legal issues.

In real life, many practitioners in the black industry and those thinking of "earning quick money" harbor a mindset of luck, believing that "overseas platforms are unregulated" or "it's just transferring money, it’s not a crime." The reality is that regardless of whether the platform is overseas or domestically located, as long as it involves Chinese citizens and harms Chinese interests, it will be subjected to Chinese legal sanctions; regardless of whether participants are actively committing crimes or passively participating, as long as they violate the law, they will bear corresponding responsibilities.

(1) Legal Responsibilities of Guarantee Platform Operators: Maximum Sentence of Life Imprisonment

According to Chinese criminal law and relevant judicial interpretations, operators of overseas guarantee platforms are primarily suspected of the following crimes:

❶ Money laundering: Providing fund accounts, assisting in converting assets to cash or financial instruments, helping to transfer funds via transfers or other settlement methods, or assisting in sending funds abroad, among other actions, related to income generated from drug crimes, organized crimes, terrorist activities, smuggling, bribery, destroying financial management orders, and financial fraud, all constituting money laundering. Severe cases can lead to a prison term of five to ten years and fines of 5% to 20% of the money laundered; if the amounts involved are particularly large and the circumstances extremely severe, the maximum sentence can reach life imprisonment.

❷ Illegal business operations: Without approval from relevant state authorities, illegally operating securities, futures, insurance, or engaging in illegal fund payment and settlement business, severe cases constitute illegal business operations. Overseas guarantee platforms are essentially illegally involved in fund payment and settlement business, severe cases can lead to less than five years of imprisonment or detention, plus fines ranging from one to five times the illegal earnings; in particularly severe circumstances, imprisonment of over five years and fines or confiscation of property can apply.

❸ Assisting information network crime activities (referred to as the accomplice crime): When knowing that others are committing crimes using information networks, providing them with internet access, server hosting, network storage, communication transmission, or providing advertising promotion and payment settlement support, severe cases constitute accomplice crimes and can result in less than three years of imprisonment or detention, plus fines or solitary penalties.

Additionally, platform operators may also be involved in multiple charges such as fraud, selling personal information of citizens, and smuggling based on specific business operations, facing multiple convictions.

It is important to note that even if a platform is registered and operates overseas, the operators are foreign nationals, as long as their business involves illegal transactions concerning Chinese citizens or harms Chinese interests, Chinese judicial authorities exercise jurisdiction. In recent years, through international judicial cooperation, China has successfully extradited multiple operators of overseas black industry platforms, demonstrating that "the law's net is vast and encompasses all."

(2) Legal Risks for Ordinary People: These Actions May Constitute Crimes!

Many people think they are only "making a little money" and won't commit serious crimes, but in reality, the following common actions may constitute crimes:

❶ Participating in money laundering through points: Accepting unfamiliar funds via one's bank card, Alipay, or WeChat through the point-earning APP provided by the platform and converting USDT to send to the platform’s designated address to earn commissions. This behavior involves accomplice crimes; even participating just once can lead to criminal liability if the amount involved exceeds a certain threshold (usually involving payment amounts over 200,000 yuan or illegal gains exceeding 10,000 yuan).

❷ Acting as a U-trader, providing exchange services for platforms: Serving as a USDT exchange intermediary between the platform and users, receiving users' RMB, transferring USDT to the platform, or vice versa to profit from the price difference. This might involve illegal business operations, accomplice crimes, or money laundering crimes, especially when the funds are known to originate from fraud or gambling, increasing the severity of sentencing.

❸ Promoting and leading: Attracting new users for guarantee platforms, earning commissions for each successful referral. This constitutes providing advertising promotion support for crimes and can lead to accomplice crime charges; even without directly participating in financial transactions, legal responsibilities apply.

❹ Renting out bank cards and phone cards: Renting one’s bank card and phone card to others for fund receiving or registration on the platform. This behavior, known as the "two-card" crime, is a common manifestation of accomplice crimes and has been a focal point of law enforcement in recent years.

Moreover, even if there is no criminal liability, participants' bank cards, Alipay, and WeChat payment accounts may still be frozen, affecting their normal lives; if involving cross-border fund flows, they could be added to credit blacklists, influencing loan and credit card applications.

(3) Legal Misconceptions: These "Excuses" Do Not Justify Acquittal

Many involved individuals attempt to defend themselves with various excuses upon arrest, but none of these justifications hold up in the face of the law:

❶ "I didn’t know this was illegal": Whether someone is aware cannot be judged solely on the individual's verbal claims; judicial authorities will comprehensively assess their cognitive abilities, exposure to circumstances, and profit situations. For instance, someone long involved in the crypto sphere cannot claim ignorance over the high likelihood of USDT points being associated with money laundering; such defenses of "unawareness" will not be accepted in such cases.

❷ "The platform is overseas, I thought it wasn't under China’s jurisdiction": As stated earlier, as long as actions harm Chinese interests or involve Chinese citizens, Chinese judicial authorities have jurisdiction; overseas does not equate to beyond the law.

❸ "I'm just a small player, and my earnings are minor": In joint crimes, even accomplices must bear criminal responsibility; however, their sentencing will be lighter than that of major offenders, but that does not absolve them from accountability.

In Conclusion: Understanding the Truth About Guarantee Platforms and the Black and Gray Industry

The core of Web3 lies in decentralization and transparency, but technology itself does not distinguish between legal and illegal; true industry practitioners uphold compliance principles, while those using technology for illegal activities will ultimately face regulatory crackdowns and be cast out by the industry.

All overseas unlicensed virtual currency guarantee platforms are, in essence, "accomplices" of the black and gray industry. What you think of as "secure guarantees" actually underwrite criminal actions, and participating in them crosses legal red lines. Beneath the surface of black market "quick money" schemes are invisible traps. Platforms may abscond with funds, assets may be frozen, and participants may become tools for crime, ultimately leading to the outcome of "not earning money, but serving time."

Lastly, it's essential to emphasize that Web3 technology holds great innovative potential, but this potential must be exercised within a framework of legality and compliance. I hope this article helps everyone bridge the information gap, recognize the "true nature" of specific guarantee platforms, stay away from the black and gray industries, and safeguard your property and freedom.

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