Case Study: Prince Group – A Masterclass in Money Laundering and Fraud

In October 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN), working closely with the United Kingdom’s Foreign, Commonwealth, and Development Office (FCDO), took complementary actions against a major cybercriminal network operating out of Southeast Asia.

Specifically, OFAC imposed sweeping sanctions on 146 targets affiliated with the Prince Group Transnational Criminal Organization (TCO) - a Cambodia-based network led by Chen Zhi. The Prince Group was found to be operating a global online investment scam empire targeting American and international victims. In parallel, FinCEN issued a final rule under Section 311 of the USA PATRIOT Act, severing Huione Group, a Cambodia-based financial services conglomerate, from access to the U.S. financial system. Huione had been laundering proceeds from virtual currency scams and cyber heists, including those linked to North Korea.

What makes the Prince Group case so important for AML professionals is not just the amount of money involved, but the structure behind it. This wasn’t a loose network of opportunistic fraudsters - it was a fully integrated criminal business model, built to scale, shield itself from scrutiny, and generate billions in illicit revenue.

How the Crime Was Built: Fraud at an Industrial Scale

At its core, the operation relied on cyber-enabled investment scams - the kind that have surged in recent years: fake trading platforms, crypto Ponzi schemes, romantic manipulation, and high-pressure “customer support” frauds. These scams were industrialized through the use of forced labor and trafficking victims.

Scam Compounds Disguised as Business Parks

The fraud was physically executed in “scam compounds”, essentially office parks outfitted with call center-like setups, where thousands of people were forced to carry out online fraud.

These weren’t employees. They were trafficking victims, forced to commit:

• Pig butchering scams: Long-game investment frauds where victims are “fattened up” through emotional manipulation and trust-building before being coerced into transferring funds into fraudulent platforms.

• Sextortion: Blackmail schemes using sexually explicit materials, often targeting minors.

• Romance fraud, phishing, and fake tech support: Often targeting lonely or vulnerable individuals, including minors.

• Crypto investment fraud: Fake apps or trading platforms that mimicked real financial services but routed funds to criminal wallets.

Each compound could have hundreds of enslaved workers operating under constant surveillance, coached in scripts, and evaluated based on how much money they brought in. Reports documented torture, rape, and even killings in some of these locations, including within Jin Bei Group, a luxury hotel and casino brand under the Prince Group’s umbrella. This is how they found their victims:

• Individuals were lured with fake job offers in customer service, tech, and finance.

• On arrival, passports and phones were confiscated, and movement was restricted.

• Victims were then forced to conduct scams, particularly pig butchering, which involves building false relationships to trick victims into investing in fake trading platforms.

• Multiple compounds operated under Jin Bei Group, a luxury hotel and casino operator tied directly to Prince Holding Group.

• Conditions inside the compounds included torture, sexual violence, isolation, extortion, and, in some cases, murder.

The Laundering Operation of Prince Group: Shell Companies, Offshore Fronts, and Crypto

The Prince Group Transnational Criminal Organization (TCO), led by Chen Zhi, built one of the most elaborate and damaging financial crime operations ever uncovered in Southeast Asia. But unlike many criminal networks, this group didn’t operate in the shadows - it built a public-facing corporate empire designed to look legitimate while facilitating cyber scams, human trafficking, and industrial-scale money laundering.

More specifically, the Prince Group TCO used over 100 shell and holding companies across Cambodia, Mauritius, Taiwan, Singapore, Laos, and Palau to facilitate movement of funds and obscure their illicit origins. Most of these companies had no genuine commercial activity but appeared legitimate on paper - often sharing the same addresses and directors.

These entities were used to:

• Move money across jurisdictions with minimal regulatory scrutiny.

• Create the appearance of legitimate investment income and business operations.

• Reinvest proceeds into real estate, hospitality, and financial services, making it harder to isolate illicit capital from legal revenue.

This structure allowed the group to layer and integrate illicit funds without drawing attention, especially when paired with the group’s legitimate business fronts.

Commercial Fronts That Looked Legitimate

The Prince Group’s greatest strength was its ability to blend criminal operations into a portfolio of real companies. These businesses gave the appearance of normal corporate growth while serving as key channels for laundering and reinvestment:

• Prince Bank Plc.: A licensed bank in Cambodia, used to manage internal flows of criminal proceeds and correspond with other financial institutions.

• Prince Huan Yu Real Estate Group: Involved in the construction and ownership of scam compounds under the guise of property development.

• Jin Bei Group Co. Ltd.: Casinos and hotels used as both fronts and locations for trafficking, fraud, and extortion operations.

• Golden Fortune Resorts World Co. Ltd.: A site publicly linked to torture and abuse of forced workers. This facility, near Phnom Penh, operated under the pretense of a technology park or resort development.

Each of these entities had public-facing legitimacy - running marketing campaigns, engaging with governments, and presenting audited financials. This façade helped them avoid scrutiny for years while laundering billions in stolen funds.

Crypto as a Laundering Tool

Crypto played a central role. Through affiliates like Warp Data Technology Lao, the group operated a bitcoin mining operation to obscure the flow of stolen funds and convert them into traceable (yet difficult-to-seize) digital assets.

Huione Group - a Cambodia-based financial services firm - was central to this laundering process. It facilitated over $4 billion in illicit transactions, including:

• $37 million in crypto from DPRK-linked cyber heists.

• $36 million from virtual currency investment scams.

• $300 million from other cyber scams.

By mixing crypto with fiat flows and routing funds through jurisdictions with weaker oversight, they maintained a sense of operational anonymity and scale.

Why It Worked for So Long

Understanding how this operation stayed afloat for over a decade requires us to look at three major blind spots:

1. Jurisdictional Arbitrage

Prince Group’s core operations were in Cambodia, where regulatory oversight is limited and enforcement cooperation with international authorities is slow. The group then used offshore centers such as Mauritius, Singapore, and Palau, to layer transactions and obscure beneficial ownership.

2. Commingling Illicit and Legitimate Revenue

Chen Zhi’s empire was built on a hybrid model: launder illicit proceeds through legitimate-looking businesses. This made it difficult for investigators or financial institutions to detect anomalies, especially when these businesses paid taxes, employed staff, and engaged in plausible commercial activity.

3. Exploitation of Financial Institutions

Entities like Prince Bank, nominally a commercial bank, played dual roles: fronting as a legitimate bank while being used internally to manage and obscure illicit flows. This insider access to the financial system allowed for wire transfers, account creation, and KYC manipulation that would be unavailable to outside actors.

Lessons for AML Professionals: What to Look For to Prevent Similar Cases

This case is a masterclass in the evolution of financial crime. For AML professionals, it’s a reminder that today’s criminals aren’t hiding in the dark corners of the system, They’re building polished facades, registering companies, and opening bank accounts like any other customer.

If you’re working in AML, this is the time to sharpen your toolkit. Here are practical red flags, behavioral patterns, and structural clues drawn directly from the Prince Group case, designed to help prevent similar cases from infiltrating your institution.

1. Shell Companies That Look Just “Legit Enough”

The Prince Group relied on more than 100 shell and holding companies to move and disguise funds. Most were dormant on the surface, but passed basic checks. What to look for:

• Shared corporate addresses across multiple unrelated companies.

• Recycled directors or shareholders across entities.

• Recently incorporated entities with immediate high-volume activity.

• Corporate websites that are non-functional or vague, often lacking staff, contact info, or services.

• Mismatch between business description and transaction activity (e.g., “consulting” firm engaging in international trade or crypto flows).

If your onboarding or enhanced due diligence relies only on incorporation documents, you will miss these risks.

2. Rapid and Unjustified International Fund Flows

Prince Group layered transactions across multiple countries - often through jurisdictions with weak regulatory enforcement or known offshore secrecy.

Watch for:

• Complex transaction chains with no clear business rationale.

• Funds sent through 3 or more jurisdictions in quick succession.

• Use of correspondent banks in high-risk jurisdictions.

• Regular transfers just below reporting thresholds, especially in structured patterns.

• Repatriation of funds into real estate, banking, or luxury sectors, especially from “consulting,” “platform,” or “service” companies.

  
  

3. Crypto Activity Without Clear Source of Funds

Crypto wasn’t just a payout mechanism - it was core to laundering. Look for:

• Crypto-to-fiat conversions coming from wallets with prior exposure to scams or OFAC-listed addresses.

• Mining-related entities that serve as a financial pass-through without verifiable output or equipment.

• Transfers from non-KYC crypto exchanges, especially in Southeast Asia or unregulated jurisdictions.

• Layered transfers involving mixers, DeFi platforms, or instant swap services, especially when combined with fiat movement shortly after.

AML teams should ensure their blockchain analytics tools are tuned to detect scam-linked wallet behavior and transaction patterns associated with human trafficking and pig-butchering scams.

4. Banks and Fintechs Used as Gateways

Prince Bank, a licensed institution, played a dual role: it served legitimate customers and helped move illicit funds. Institutions should assess:

• Unusual patterns in affiliated financial institutions, especially if they hold licenses in weak regulatory environments.

• Private banks or niche retail banks dealing in high-risk corridors without a clear customer profile.

• New or small financial institutions showing sudden growth in cross-border volumes or crypto-fiat flows.

This includes looking retrospectively at past transactions, particularly those involving newly sanctioned entities or jurisdictions now under scrutiny.

5. Entities with High Marketing Spend but No Operational Footprint

Prince Group invested in marketing, PR, and lobbying to appear credible. However, behind the façade, there was little genuine economic activity in many of its entities.

Ask:

• Does this entity have staff, premises, inventory, or service delivery capacity in proportion to the funds it’s moving?

• Is it spending significantly on advertising, sponsorships, or influencer marketing with no supporting revenue?

• Are there signs of government partnerships, awards, or local affiliations used to mask credibility, without audited financials or commercial proof?

Scammers are increasingly media-savvy. Don’t mistake brand polish for legitimacy.

6. Labor or Travel Patterns Linked to Forced Work Sites

In the Prince Group case, victims were trafficked from abroad to scam compounds. Financial indicators of this include:

• Travel expense reimbursements, visa payments, or cross-border payrolls tied to remote employers with no presence in the employee’s home country.

• Transfers to or from border towns or industrial zones with no business rationale.

• Salary payments to multiple individuals who later send or receive transfers to known scam hubs (Cambodia, Myanmar, Laos, Palau).

This is where AML and human trafficking detection efforts must align. Transaction behavior of victims often gets misread as criminal conduct unless seen in context.

Final Thoughts

The Prince Group case is a wake-up call for every compliance team still relying on traditional indicators of risk. It demonstrates how financial crime today is not only digital — it’s corporate, networked, and scalable. What began as a series of scams evolved into a multinational operation hiding behind legitimate structures, licensed institutions, and even public goodwill.

For AML professionals, this means the next major scandal may not emerge from the shadows but from an entity that looks  - on paper - entirely legitimate. The challenge is to move beyond surface-level compliance and into pattern recognition, behavioral analysis, and cross-border intelligence sharing.

Criminal enterprises are learning faster than ever; so must we. Effective compliance now depends on connecting human judgment with data, asking uncomfortable questions, and protecting integrity even when it’s inconvenient.