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Say i make a website, a website where you can deposit "virtual" currency, as in credits from an RPG or any other game that allows ingame trading with other players. after a deposit, players are awarded a certain amount of "credits". The players can use those credits to gamble on the website. When a player is done gambling, he/she can cash out the site "credits" back to the currency of the game he used for his deposit.

The cashin/cashout process will be done by manual 1 on 1 in the game of choice. The website will only do cashin/cashouts with virtual game currency, and will not allow any direct way to convert your curreny/credits to real cash.

the virtual currency could have a real money value on the game's black market (unofficial, not sold or bought by the game devs, usually against the game's terms of service), but the website won't have any direct ties to that.

does anyone know if a gambling license is required for a website like this?

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    Lemme get this straight. It's entirely fake in-game currency, and there would be no way, inside or outside the ToS, to turn USD into game currency or game currency into USD or any other out-of-game-universe good that people normally pay cash for. And it wouldn't be obvious nor make sense to in the future start charging USD for game currency. Is that correct? – Harper - Reinstate Monica Nov 22 '17 at 21:32
  • @Harper the currency is not directly worth money. the only value the currency has is a player-to-player value. So the only way to actually turn your "credits" in USD, will not be done on the website – FrankK Nov 23 '17 at 11:09
  • Do you expect people to be doing third party trading of your currency? Do you plan to do anything to enable this? E.g. If I give Jim $100 for 100k currency in your game, will you provide a way for Jim to simply transfer me the currency, if so, what other purpose would that have? ... Or would we have to go into a 1on1 game and he lose a bunch of games to me? (I.e. If you randomly match players or minimum game size is 5, that would make it hard.) Will you aggressively try to prevent currency trading with TOS enforcement, or do you nudge-wink expect/hope it happens? – Harper - Reinstate Monica Nov 23 '17 at 11:34
  • @Harper sorry for my delayed response, I will update the post to clarify the situation some more – FrankK Nov 24 '17 at 8:57
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Not yet illegal. But several companies like Valve have taken action to stop this exact thing.

Your biggest worry isnt to be stopped by the authorities (yet, after this EA debacle that might change at least in the EU).

Your problem is that such a site is almost certainly against the TOS of the game, so can be an easy target for lawsuits from the games publisher.

To be more clear: when your players deposit in game currency, your sites accounts holding those deposits for later redistribution will be violating the games TOS, and so can be shut down at any time

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