{ "compartment_id": "section-11", "number": "Section 11", "title_local": "The July 2016 notice and the Washington record", "title_english": "The July 2016 notice and the Washington record", "source_url": "https://phishdestroy.io/steam_dossier/#case-study-section", "source_document": "index.html", "content": { "html": "
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\nPart B — Rules and enforcement record · Section 11\n

Ten days demanded. Ten years to account for.

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Context & source limits

On 20 July 2016 Valve's general counsel gave gambling operators a 10-day deadline. Ten years later (as of the dossier snapshot, 2026-09-21) at least one platform named in press reports of that notice, CSGOFast, is still operational with a separate-domain auth host. The wording is reconstructed below from press reports of 21 July 2016; the reconstruction is not a scan. The enforcement record the notice implied has not been published. The open letter to the Commission is Section 2.

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Read the July 2016 notice beside the later observations. The outstanding demand is an operator-by-operator enforcement record.

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\nOne week earlier — 13 July 2016, in public\n

On 13 July 2016 archived 2026-09-21 ↗, Valve described how gambling sites used Steam: OpenID for account identification and automated accounts for trading. Valve stated that using those mechanisms to run a gambling business violated its API and user agreements. Both the description of the mechanism and the prohibition are in Valve's own dated statement. On 2026-09-21 the separate-domain auth hosts tested returned no Link Filter block, and Valve has published no per-operator enforcement record.

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VALVE CORPORATION

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Bellevue, WA

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DATE: July 2016 (reported by press 21 July 2016)
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FROM: Karl Quackenbush, General Counsel
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RE: Cease and desist — commercial use of Steam accounts
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NOTE: Reconstruction of reported text; not a scan
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\"We are aware that you are operating one of the gambling sites listed below. You are using Steam accounts to conduct this business. Under the Steam Subscriber Agreement, Steam and Steam services are licensed for personal, non-commercial use only.\"

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\"You should immediately cease and desist further use of your Steam accounts for any commercial purposes. If you fail to do this within ten (10) days, Valve will pursue all available remedies including without limitation terminating your accounts.\"

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\nReconstruction of the July 2016 notice text, rendered by the authors from press reports of 21 July 2016\n
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Karl Quackenbush
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General Counsel, Valve Corp.
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\nTimeline\nJuly 2016 – September 2026\n
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Deadline in the notice:
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10 Days
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July 2016
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Elapsed since the notice:
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3,715 Days
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Fixed count from 20 July 2016 to the dossier snapshot of 21 September 2026, not a live figure
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Published enforcement record:
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None
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No per-operator account of terminations or blocks located
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◀ Days 0–10 — the deadline, to scaleDay 3715 — the snapshot ▶

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  1. Ten-day demand issuedDay 0
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  2. DSA obligations applyDay 2,768
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  3. NY AG complaint announcedDay 3,507
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  4. Dossier snapshotDay 3715
    5. \n
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\n Ten years later, CSGOFast — named in press reports of the 2016 notices — is operational: csgofast.com returned a Link Filter block on 2026-09-19 and 2026-09-21, while its auth host steam-login.authtofast.com (registered 2026-06-30) did not.\n

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Full dated record of Valve's security changes: Security Timeline → · The Washington record and the enforcement standard: below

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\nWhat the record shows: the 2016 notice set a 10-day deadline; Valve already operated a domain list (the Link Filter) and received the auth hostnames in its own OpenID requests; no per-operator enforcement record has been published. Community reports describe a 2018 action against a marketplace (SkinJar), but those reports are unverified and are not relied on here.\n
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PUBLIC RECORD / WASHINGTON · 2016 → 2026

Two deadlines. One unanswered enforcement standard.

20 JUL

Valve gives gambling sites 10 days

Its counsel's demand warned that continued commercial use of Steam accounts could lead to termination.

27 SEP

Washington presses Valve

The state's Gambling Commission demanded evidence of steps to stop skin transfers for gambling and set a 14 October response deadline.

17 OCT

Valve rejects the charge

Valve answered after the deadline, disputed that it facilitated gambling, said it had disabled associated accounts, and said it did not want to switch off trading and OpenID for everyone. At least one platform named in press reports of the July notices (CSGOFast) was operating a decade later. Both facts can hold only if the operator replaced the disabled accounts; the record that would show this has not been published. The WSGC should ask Valve to reconcile the two.

2026

The routes observed in September 2026

The route register records 44 platforms authenticating through separate-domain auth hosts, including CSGOFast, using the OpenID and trading mechanisms Valve described in 2016. The enforcement record that would show which operators were cut off has not been produced.

\nTHE COMMISSION'S OWN BRIEFING · 30 JANUARY 2018\n

Eighteen months after Valve replied, the regulator still called it an intent.

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Briefing its own legislature at the HB 2881 public hearing, the Commission described the July 2016 statement in its own words: Valve \"announced its intent to crack down on the use of its platform to facilitate skins gambling.\" The same page records what that announcement did to the industry forecast — \"as a result,\" the projected 2020 skin-gambling market was revised from $19.7 billion to $670 million, a cut of about 97 per cent, on the strength of the announcement alone. The forecast moved. The per-operator enforcement record that would justify it has still not been published.

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The market figures are Narus Advisors / Eilers & Krejcik Gaming estimates reproduced in the Commission's briefing, not Commission findings; the same document puts 2016 skin wagering at about $5 billion, roughly $3 billion of it on casino-style sites. Retrieved 2026-09-22, SHA-256 c507c9025f93da0aadaf395c4d8882f25973211c318ee8e9b6f18a5b3755e050.

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Valve's public 2016 position and today's observable infrastructure can be put side by side. The question is whether enforcement reached the accounts and routes used by prohibited operators. A ten-day notice is not evidence that the notice was carried out across the operators it named. The 2018 OPSkins action is the one documented intervention against a named operator; set against 189 platforms checked and no published per-operator record, one documented action does not show a pattern of enforcement.

Washington Gambling Commission's 2016 notice ↗ archived 2026-05-20 ↗ · Valve's 17 October 2016 response (document copy) ↗ · WSGC briefing to the legislature, 30 January 2018 (local copy, 4 pp.) ↗ · the same file on wsgc.wa.gov ↗ · retrieval record & hash ↗ · Valve's 2018 OPSkins action ↗ archived 2026-03-07 ↗ · Current route audit ↗

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\nForensic Longitudinal Audit · 2016 Cease & Desist Targets\n

The 10-Day Notice Decade: Forensic Survival Audit of the 23 Named Sites

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On 19–20 July 2016, Valve General Counsel Karl Quackenbush issued formal cease-and-desist notices to 23 skin gambling platforms, ordering them to cease commercial use of Steam accounts within 10 days under threat of account termination and legal action. Over 3,700 days later, an empirical audit reveals the true pattern of enforcement: multiple operators never ceased operations, others ran for up to six years after the deadline, and the multi-billion-dollar ecosystem continued to leverage Valve's OpenID architecture.

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5+ LIVE
Defiantly operational in 2026 (CSGOBig, CSGO500, CSGOFast, etc.)
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6 YEARS
Longest post-notice run before closure (CSGOatse active through 2022)
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$5.01B
2016 skin wagering volume (Narus / Eilers & Krejcik)
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200+
Active skin gambling sites operating at market peak
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Platform / DomainJuly 2016 NoticeEnforcement Outcome & Survival StatusRecorded Verification / Primary Links
CSGOBig
csgobig.com		10-Day Notice (Jul 2016)STILL LIVE IN 2026
Temporarily paused, relaunched; authenticates via letmeinbig.com & csgobiglogin.com		X: @csgobig ↗ · FB: csgobigofficial ↗
CSGO500
csgo500.com / 500.casino		10-Day Notice (Jul 2016)STILL LIVE IN 2026
Rebranded into 500 Casino (Curaçao license #8048/JAZ2014-037), multi-million monthly turnover		Live Platform (500.casino) ↗
CSGOFast
csgofast.com		10-Day Notice (Jul 2016)STILL LIVE IN 2026
Actively operating roulette, crash, and jackpot via steam-login.authtofast.com		Dossier Auth Audit ↗
CSGOLounge / Dota2Lounge
csgolounge.com / dota2lounge.com		10-Day Notice (Jul 2016)STILL LIVE IN 2026
Pivoted to esports coin wagering and crypto betting; maintained continuous operation		Live Platform ↗
CSGOCasino
csgocasino.net / csgocasino.gg		10-Day Notice (Jul 2016)LIVE VIA SUCCESSOR (2026)
Domain redirected; active successor portal operates under csgocasino.gg		Successor Domain ↗
CSGOatse
csgoatse.com		10-Day Notice (Jul 2016)SURVIVED 6 YEARS (ACTIVE TO 2022)
Continued full gambling operations for six years following Valve's 10-day ultimatum		X: @CSGOatsecom (Active to 2022) ↗
CSGOSweep
csgosweep.com		10-Day Notice (Jul 2016)SURVIVED TO DEC 2017
Operated publicly for 17 months after deadline		X: CSGOSweep Status Dec 2017 ↗
CSGOWild
csgowild.com		10-Day Notice (Jul 2016)SURVIVED TO DEC 2017
Promoted by major influencers; ran for 1.5 years post-C&D before crypto migration		X: @Wild (Active Dec 2017) ↗
CSGOPot
csgopot.com		10-Day Notice (Jul 2016)SURVIVED TO SEPT 2017
Operated high-stakes jackpot betting 14 months past notice		X: @csgopot (Active Sep 2017) ↗
CSGODiamonds
csgodiamonds.com		10-Day Notice (Jul 2016)SURVIVED TO MID 2017
Ran through 2017 despite admitted outcome tampering for sponsored streamers		X: @csgodiamondscom (2017) ↗
CSGOLotto
csgolotto.com		10-Day Notice (Jul 2016)CLOSED JULY 2016
Shut down under public scandal; target of federal FTC consent order		FTC Consent Order (Docket C-4632) ↗
CSGODouble
csgodouble.com		10-Day Notice (Jul 2016)CLOSED JULY 2016
Shut down voluntarily immediately after C&D publication		X: @CSGODouble (Closed Jul 2016) ↗
CSGOMassive
csgomassive.com		10-Day Notice (Jul 2016)CLOSED 2016
Ceased public operations in late 2016		X: @csgo_massive ↗
CSGOStrong
csgostrong.com		10-Day Notice (Jul 2016)CLOSED 2016
Ceased public operations in 2016		FB: csgostrongfree ↗
Skins2
skins2.com		10-Day Notice (Jul 2016)CLOSED 2016
Ceased public operations in 2016		FB: CSNCOM ↗
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\nThe Surviving Titans · 2024–2026 Financial & Traffic Blueprint\n

From 10-Day Warnings to Offshore Conglomerates: The Multi-Billion-Dollar Turnover

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Rather than eliminating skin gambling, Valve's 2016 notices catalyzed an industrial evolution. The surviving operators restructured as offshore corporate entities (Curaçao, Belize, Cyprus), pioneered Peer-to-Peer (P2P) trading to bypass bot bans, and now process over 10 million monthly web visits and billions of dollars in annual wagering handle while continuing to authenticate through Steam:

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PlatformMonthly Traffic (Visits)Estimated Turnover / VolumeCorporate Entity & JurisdictionKey Regulatory Actions & Model
CSGOEmpire
csgoempire.com		2.3M — 9.0M / mo
Avg 6+ min duration; 80% direct		$1.5B — $2.5B Annual Handle
>1,000,000 P2P skin trades/mo; $6.4M active liquid order floor		Moonrail Limited B.V. (Curaçao #148182)
Payments: JHOLT LTD (Cyprus); Founder: \"Monarch\" (Ossi Ketola)		Pioneered 0% fee P2P item trading; licensed Curaçao OGL/2024/1183/0869
CSGORoll
csgoroll.com		2.74M — 3.5M / mo
Avg 9m 23s duration; 16% bounce rate		$1.0B — $2.0B Annual Handle
Est. $100M–$200M annual corporate revenue from house edge		Feral Holdings Limited
Headquartered in Belize City, Belize (Reg #171519)		Banned by Australian ACMA (May 2023); sponsored tier-1 team G2 Esports with underage players
500 Casino (CSGO500)
500.casino / csgo500.com		220K — 425K / mo
~105k unique monthly visitors		$100k / week ($5.2M/yr) in Royales
High-roller wagering requirement: $400 wager per $1 rakeback		Perfect Storm B.V. (Curaçao #150536)
Curaçao Gaming Control Board license OGL/2024/1354/0882		Banned by Swedish Spelinspektionen (Nov 2023) for unlicensed targeting of Swedish players
CSGOBig
csgobig.com		~169,600 / mo
Avg duration 19m 12s; US primary		Multi-Million Annual Volume
Mystery boxes, roulette, and case battles		Operates via auxiliary proxy routing
letmeinbig.com (reg 2023) & csgobiglogin.com		Target of July 2016 C&D; relaunched with proxy auth architecture
CSGOFast
csgofast.com		~150K — 250K / mo
Global multi-language audience		Multi-Million Annual Volume
High-velocity roulette and crash games		Offshore operational entities
Routes Steam auth via steam-login.authtofast.com		Target of July 2016 C&D; never discontinued operations; active in 2026
CSGOPolygon
csgopolygon.com / plg.bet		~300K — 500K / mo
CIS and Eastern European dominance		Multi-Million Annual Volume
Crypto & skin roulette, match betting		Second-wave target (Oct 2016)
Pivoted to cryptocurrency with mirror domain plg.bet		Survived a full decade; continues skin liquidation via third-party APIs
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The Second Wave: Why Valve's C&D Targeted 43+ Sites in Total
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\nOn 17 October 2016, Valve's legal counsel formally disclosed to the Washington State Gambling Commission that following the initial 23 notices on July 19, Valve had sent cease-and-desist letters to more than 20 additional skin gambling sites (bringing the official total above 43). This second wave was necessitated because the initial list inexplicably omitted the largest, most notorious gambling hubs in the world:\n

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  • CSGOJackpot.com: The historic originator of skin jackpots, which handled hundreds of millions in volume before shuttering under threat of federal indictment.
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  • CSGOShuffle.com: The site at the heart of the July 2016 streaming scandal, where Twitch streamer PhantomL0rd secretly owned 33% of the company and was exposed rigging odds with house funds.
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  • The Macro Ecosystem (200+ Operators): According to industry research by Narus Advisors and Eilers & Krejcik Gaming, over 200 distinct skin gambling sites operated in 2016, generating $5.01 Billion in wagering volume from 3.03 million active players. Valve's 43 letters addressed less than 20% of the active market.
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Official Government & Regulatory Investigations on Steam Skin Gambling
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The skin gambling phenomenon is documented across multiple formal statutory inquiries, enforcement actions, and government position papers:

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\n1. Washington State Gambling Commission (WSGC) (2016–2018)\n

Issued formal Cease & Desist demand on 5 Oct 2016; published Legislative Briefing on 30 Jan 2018 documenting that skins are cash equivalents and reporting the $5.0B skin wagering volume.

\nWSGC Legislative Report PDF (Local Copy) ↗\n
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\n2. U.S. Federal Trade Commission (FTC) (Sept 2017, Docket C-4632)\n

First federal regulatory enforcement action involving skin gambling against CSGOLotto owners Trevor Martin and Thomas Cassell for deceptive practices and undisclosed platform control.

\nFTC Decision & Consent Order ↗\n
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\n3. UK Gambling Commission (UKGC) Position Paper & Youth Audits\n

The Commission treats in-game items convertible to cash as money’s worth. Its 2018 survey found that 3% of 11–16-year-olds said they had ever bet with in-game items (skins).

\nUKGC 2018 youth survey ↗
UKGC position on virtual currencies ↗\n
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\n4. Australian Senate Environment & Communications Inquiry (2018)\n

Federal Parliamentary report on \"Gaming micro-transactions for chance-based items\", evaluating Valve's loot box mechanics, secondary market cashouts, and regulatory circumvention.

\nParliament of Australia Inquiry ↗\n
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\nThe outstanding demand\n

Publish the enforcement record: which gambling accounts and bots were disabled, which return hosts were restricted, and which commercial services received permission. A public prohibition and a homepage warning do not establish that the underlying operation was stopped.

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