因此，了解周焯华实施的行为哪些属于关键行为至关重要。涂远钊认为，涉嫌犯罪的关键行为主要有组织中国公民赴境外赌厅赌博或者参与跨境网络赌博活动，该行为是构成开设赌场罪的核心要素。其次，周焯华在中国境内协助客户进行非法跨境资金兑付，同时利用地下钱庄等非法渠道为赌客提供资金结算服务，该行为涉嫌非法经营罪。
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