从温州市公安局公布�?《案情通报》可以看出，周焯华的行为包括在澳门承包赌厅，在菲律宾等地开设赌博网站；发展中国内地人员为股东级代理和赌博代理；以高额报酬或奖金形式组织人员向代理以及内地居民推广赌博网站或境外赌厅；以提供高额佣金利诱各级代理组织内地居民在赌博网站赌博或赴境外赌博；在内地成立资产管理公司，为赌客用资产换取赌博筹码提供服务、帮助索要赌债、协助赌客进行跨境资金兑付；利用地下钱庄等非法渠道为赌客提供赌资支付结算；为便于代理发展和管理下线、推广赌厅跨境赌博业务或跨境网络赌博平台，通过内地技术公司提供赌客管理、车辆服务等技术支持。
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北京市盈科（珠海）律师事务所律师涂远钊告诉南方财经全媒体记者，上述行为是跨境赌博犯罪的整体，既有辅助行为，也有关键行为。如果仅有辅助行为，没有关键行为，并不涉嫌犯罪。他举例，“比如仅在境外赌场承包赌厅和开设赌博网站，没有组织中国内地居民参赌，并不构成开设赌场罪。”