Introduction

In October 2025, the U.S. government unsealed charges against Cambodian businessman Chen Zhi, accused of orchestrating a cryptocurrency scam of staggering scale - described by authorities as “one of the largest investment fraud operations in history.” The proceeds allegedly funded a life of excess, including yachts, private jets, luxury properties and fine art.

According to the U.S. Department of Justice, Chen’s vast network of over 100 shell and holding companies funnelled profits from a global cryptocurrency fraud operation through a labyrinth of legitimate business fronts, including online gambling, crypto mining and real estate. The indictment also accuses Chen and his associates of forced labour and human trafficking, allegedly using violence and coercion to staff scam compounds across Cambodia.

This case study explores how a sophisticated web of shell companies, high-risk sectors and political protection enabled Chen’s multi-billion-dollar enterprise to operate undetected for years. It highlights the growing convergence of cyber-enabled fraud, corruption, and transnational crime, and how governments are increasingly turning to sanctions and cross-border cooperation to disrupt these global criminal networks.