Client : Confidential
Completed : Q1 2025
At Themis, the confidentiality of our clients – and of the individuals and teams involved in our investigations – is paramount. While the following case study is based on a real investigation successfully completed in early 2025, we have redacted any identifying details in line with our professional and ethical commitments.
This case highlights the depth of expertise within the Themis Intelligence team and demonstrates the value of Enhanced Due Diligence (EDD) in uncovering hidden risk, particularly in complex cross-border structures and opaque industries.
Using a simple form on our website, a global private bank approached Themis for help conducting Enhanced Due Diligence on a high-net-worth individual: a Vietnamese national living in Hong Kong. The subject was a shareholder in numerous businesses spread across Asia, including the Philippines, Taiwan, and Singapore, as well as linked to entities in secrecy jurisdictions such as Bermuda and Cyprus.
The bank sought to validate the subject’s claimed source of wealth – primarily inherited from family-run businesses – and to investigate possible undisclosed links to the gambling industry before proceeding with onboarding.
The case presented several investigative challenges:
The subject had an unusually limited digital footprint for someone allegedly leading multinational companies.
Many of the associated entities were incorporated in opaque jurisdictions.
The industries in question carried high financial crime risks, including the gambling sector, which is often associated with money laundering and trafficking in the region.
The Themis Intelligence team applied a multi-layered, multilingual investigative approach to build a clear profile of the subject and their business interests. Key techniques included:
Corporate mapping of over a dozen entities across jurisdictions, revealing hidden relationships and nominee structures.
Analysis of historical digital footprints, including retrieval of de-indexed and archived content, showing past ties to e-gaming product development.
Screening of associates, which identified links to gambling consultancies and strategy firms operating out of Cyprus.
Local-language media research, which uncovered a Thai news source linking the subject to six companies tied to a Cambodian border-town casino operation.
This Cambodian operation was located in a well-documented hub for gambling-related crime, including forced labour, human trafficking, and money laundering.
One of the subject’s companies had previously promoted e-gaming products before quietly removing related materials from its website.
Associates included individuals working at gambling consultancy firms in Cyprus – a known hotspot for strategic online gambling operations.
Multiple entities were traced back to a Cambodian casino business, raising red flags for significant financial crime and reputational risk.
The investigation equipped the client with detailed insights into the subject’s source of wealth, corporate affiliations, and exposure to high-risk industries. Based on our findings, the client was able to make a fully informed decision regarding onboarding, weighing the legal, regulatory, and reputational implications with confidence.
This case underscores the vital role of intelligence-led EDD in uncovering hidden financial crime risks—particularly where conventional screening fails to detect deeper issues.
The Themis Intelligence team was engaged by a global private bank to investigate a Vietnamese national domiciled in Hong Kong who was a shareholder of a series of companies based across Asia, including in the Philippines, Taiwan and Singapore. The individual was also connected to a network of companies based in secrecy jurisdictions such as Bermuda and Cyprus.
Before onboarding the subject, our client wanted to gain insight into the individual’s background and source of wealth, purportedly stemming in large part from inherited wealth derived from family businesses. Moreover, the client required our help to assuage concerns relating to the individual’s potential undisclosed connections to the gambling industry.
In conducting our Enhanced Due Diligence, the team found the subject to have an incredibly limited online profile, highly uncharacteristic of an individual connected to an extensive network of companies, several with global operations and significant revenue. Nonetheless, by mapping out this web of entities and the directors associated with them, our analysts were able to make a series of key findings pertaining to financial crime risk.
By retrieving unindexed website information, our team was able to identify that one of the subject’s companies previously developed products for the e-gaming industry, before removing the related marketing content from their site. Screening of the Global Ultimate Owner of one of our subject’s companies also found associates to executives working in online-gambling strategy consultancies based in Cyprus.
Furthermore, our analysts used multilingual media searches to identify a Thai news source linking the subject to six entities which, throughout the course of our investigation, would be revealed to be connected to a casino business based in a Cambodian town renowned as a gambling hotspot where forced labour, human trafficking, money laundering and other abuses are prevalent.
By identifying these associations, we were able to answer our client’s questions relating to the subject’s source of wealth as visible on open sources and provide them with detailed information pertaining to the potential financial crime and reputational risk exposure posed by interaction with the subject.
