Articles

Introduction

A silent digital war is unfolding in Southeast Asia, where cyber scam operations have deceived thousands into digital slavery, revealing the frightening scale of modern transnational organised crime. Organised criminal syndicates trafficked innocent job seekers from around the world and recruited many scammers to form a “cybercriminal labour force” of at least 350,000 people in the region (Parry, 2025). By tricking thousands of victims into exhausting their life savings, an approximate illicit revenue in the scam industry may have generated as much as 75 billion United States dollars (USD) (Parry, 2025). How is this scenario even possible? 

Ranked 20th in the world for its high level of criminal activity, Cambodia has been identified as one of the primary hotspots of scam compounds involving cyber slavery (Wen, 2025). Recent exposure of systematic money laundering schemes in this country shone a spotlight on Huione Group, a holding company headquartered in Phnom Penh. Through one of its subsidiaries, Huione Guarantee (now rebranded as Haowang Guarantee), investigators have estimated that 24 billion USD in illicit funds were processed through Huione Group between 2021 and 2024 (Chainalysis Team, 2025).

The vast scale of criminal proceeds and the complexity of Huione Group’s business operations have become an international concern, as many people have been trafficked and scammed. To understand how Huione Group facilitated human rights abuses in Cambodia, this article will navigate Huione Group’s subsidiaries and discuss key challenges, namely the complexity of the money laundering process, the continuity of Huione Group’s subsidiaries, and the suspected involvement of Cambodian officials.

Huione Guarantee: Flourishing Illicit Online Marketplace

Huione Guarantee was a Chinese-language online marketplace that emerged as a “one-stop shop” platform for illicit trade and money laundering services (Elliptic Research, 2025). Its users multiplied to over 900,000 vendors, making it one of the largest illicit marketplaces in the world (UNODC ROSEAP, 2025). Huione Guarantee enabled criminals to trade services, technologies, and resources listed below:

• Money laundering services: unfreezing illicit funds in different jurisdictions and local financial institutions, and setting up mule accounts.
• Stolen data: Sensitive data from privacy breaches and compromised social media accounts. 
• Technological solutions: Mechanisms to bypass authentication and stay anonymous, Artificial Intelligence (AI)-powered automation and deepfake software, and synthetic identities.
• Resources for criminal activities: scam content (kits, scripts, photos, videos, etc.), Starlink satellites, and pre-registered SIM cards procurement. (UNODC ROSEAP, 2025; TRM, 2025).

To facilitate illicit money movements in Huione Guarantee, Huione Group’s ecosystem embedded at least two payment channels: Huione Pay PLC, an institution processing financial transactions through cash and transfers, and Huione Crypto, a virtual assets service provider (VASP), which is a platform for cryptocurrency transactions, trading, and exchange (Shetret, 2025). These channels are exploited by criminals due to their typically weak enforcement and regulation (UNODC ROSEAP, 2025). Apart from an estimated circulation of 24 billion USD, an additional six billion USD has been processed through these entities via associated agents or bots on a messaging application, Telegram (UNODC ROSEAP, 2025; Chainalysis Team, 2025).

Huione Group’s payment mechanisms not only enabled complex illicit transactions, but Telegram has also been utilised to assist covert communications for illegal dealings of criminal resources and services. Criminals operating on Huione Guarantee exploit an encrypted and unregulated channel on Telegram to coordinate deals with brokers or clients (Chainalysis Team, 2025). Without requiring any registered domain or physical business establishment, all parties involved in scam businesses and money laundering opted for Telegram because they can operate pseudonymously (Chainalysis Team, 2025). 

Key Challenges Surrounding Huione Group’s Services 

Complexity of the money laundering process

Different entities associated with the Huione Group demonstrate the complexity of the money laundering process (Shetret, 2025). Money laundering is conventionally understood as “the process of transforming illegally obtained funds [or ‘dirty money’] into seemingly legitimate assets, making it difficult to trace the true source of the funds and use them for criminal activities” (Financial Crime Academy, 2025). The money laundering process can be broken down into three stages:

• Placement: Illicit funds from criminal wrongdoings are deposited into the legitimate financial system.
• Layering: Illicit funds are transferred multiple times to conceal the source.
• Integration: Once laundered, illicit funds are made available in legitimate sources for further exploitation (Financial Crime Academy, 2025).

Regarding the case of Huione Group, blockchain experts discovered money laundering services of Huione Guarantee when they investigated separate cases of American citizens whose cryptocurrency assets had been defrauded (UNODC ROSEAP, 2025). There have also been similar incidents in high-income countries when digital wallets associated with Huione Group have been found as a direct destination of stolen assets (UNODC ROSEAP, 2025). 

When applying the stages of money laundering to the case of Huione Group, the complexity of Huione Group and its subsidiaries prevents detection by law enforcement and financial authorities (Shetret, 2025). While Huione Pay PLC acts as a traditional payment processor, diverse digital assets such as cryptocurrency are involved in the layering process through Huione Crypto. Moreover, Huione Group exploits different jurisdictions, including Canada, China, Poland, and Singapore, to evade financial compliance oversight (Shetret, 2025; UNODC ROSEAP, 2025).

Continuity of Huione Group’s subsidiaries

Following international media criticisms, Huione Group’s subsidiaries were investigated and faced the consequences in the first half of 2025. 

• January: Google Play and the Apple App Store decided to remove Huione Crypto (UNODC ROSEAP, 2025). 
• March: The National Bank of Cambodia withdrew Huione Pay’s license for payment services due to non-compliance (Davies, 2025).
• May: The United States’ (US) Financial Crime Enforcement Network (FinCEN) proposed the removal of Huione Group’s access to the US financial systems (FinCEN, 2025; TRM, 2025).

Despite these efforts, Huione Guarantee managed to rename itself to Haowang Guarantee and continue operating as if it had not been disrupted (UNODC ROSEAP, 2025). Prior to the investigations, Huione Guarantee also acquired 30 percent ownership of Tudao Guarantee, another illicit online platform, and registered Xone Investment, a website for a blockchain network (UNODC ROSEAP, 2025). Huione Pay PLC also announced its migration to Japan and Canada after obtaining business licenses (UNODC ROSEAP, 2025). 

Suspected involvement of Cambodian officials

As Huione Group’s subsidiaries continue to operate, whether the Cambodian government is committed to holding these entities accountable has become questionable. In May 2025, explosive news emerged when a report published by the Humanity Research Consultancy highlighted the suspected involvement of Cambodian high-profile politicians from the Cambodian People’s Party (CPP) in the cyber scam operations (Sims, 2025). 

For example, one of the sitting directors of Huione Pay PLC turned out to be Hun To, a cousin of Cambodian Prime Minister Hun Manet (Parry, 2025; Hutt, 2025). Sar Sokha, the Deputy Prime Minister and the Minister of Interior, may also have invested in the construction of scam facilities (Parry, 2025). In 2024, Ly Yong Phat, a senator closely linked to the Hun family, was sanctioned by the US due to his alleged involvement in the scam industry (Hutt, 2025).

In response, the Cambodian government strongly denied these allegations, citing that the report was “politically motivated” while asserting that it was “a tool to blame smaller countries that are technologically weak” (Khmer Times Staff, 2025). The Cambodian government stated that it had taken measures to eradicate scam operations, human trafficking, and money laundering by formulating national strategies and establishing special task forces as well as scam reporting channels (Khmer Times Staff, 2025). 

However, revoking Huione Pay PLC’s banking license is not enough. Government critics have noted that journalists investigating cybercrime have been constantly suppressed, meaning honest reporting on alleged politicians is not entirely possible (Wen, 2025; Thang, 2025). Moreover, a report released by Amnesty International highlighted that the government’s response has been inadequate (Amnesty International, 2025). Instead, the ruling party has prioritised border disputes with Thailand over tackling cyber scam operations and investigating the alleged officials (Hutt, 2025; Rainsy, 2025). 

It remains suspicious whether the CPP is genuine in its efforts to combat transnational organised crime because the border flare-ups occurred only a few months after Thailand took serious actions to disrupt scam networks (Hutt, 2025; Rainsy, 2025). Taking the disputes to the International Court of Justice alone does not demonstrate that Cambodia is a peaceful member of the international community. If Cambodia is truly committed to international law and cooperation, the Cambodian government will have to prove its willingness to seriously eradicate scam operations and human trafficking networks with concrete evidence (Hutt, 2025; Rainsy, 2025; Amnesty International, 2025).

Conclusion: Human Rights Implications for the Financial Sector and VASPs at an International Level

Considering the international scale of Huione Group’s businesses, its continuing operations, and the suspicious involvement of Cambodian officials, the case of Huione Group raises alarming concerns that financial institutions and VASPs may have unknowingly facilitated money laundering, which enables human rights abuses and hinders law enforcement efforts (UNODC ROSEAP, 2025).

As Elliptic Research (2025) highlights, “Huione Guarantee was just the tip of the iceberg”. A large number of vendors on Huione Guarantee diversified their service provisions to other platforms to extend the reach of their advertisements and used Telegram to connect with like-minded criminals. This pattern allows vendors to ensure their illicit businesses can continue if one platform is disrupted, indicating that Huione Guarantee is not the only one (Chainalysis Team, 2025). The emergence of other illicit online marketplaces requires comprehensive measures at an international level, particularly the intensification of cooperation among police authorities and financial regulators in information sharing, technical support, and capacity building (UNDP, 2025; UNODC ROSEAP, 2025).

To prevent further human rights abuses facilitated by money laundering schemes, the financial sector and VASPs around the world should promote responsible banking and digital asset services. To ensure that businesses in their systems comply with such responsibilities, the financial sector should encourage the adoption of human rights due diligence (HRDD), while VASPs should consider undertaking the Know-Your-Customer process (KYC) (UNDP, 2021; Mammadova & Bosatta, 2022). 

HRDD allows the assessment of human rights risks in legitimate businesses and investments, including whether human rights abuse activities occur in their supply chains that may harm their operations (UNDP, 2021). The HRDD process requires screening, tracking, monitoring, and communicating with relevant stakeholders to ensure that human rights are respected throughout business engagements (UNDP, 2021). The case of Huione Group demonstrates that while the implementation of HRDD can be complicated, HRDD would provide a framework for financial experts to develop a comprehensive strategy against transnational money laundering schemes that support human rights violations (UNDP, 2021; Aydin, 2021).

At the same time, the KYC process can help VASPs prevent the facilitation of human rights abuses through cryptocurrency exchange (Mammadova & Bosatta, 2022). KYC is the process by which personally identifiable information (PII) is collected for customer verification and references, allowing authorities to cross-check with criminal records (Mammadova & Bosatta, 2022). However, unlike traditional banking, VASPs are designed to be decentralised and pseudonymous, meaning that collecting PII has not been set as a strict requirement (Mammadova & Bosatta, 2022). 

As scam operations and money laundering schemes continue to persist, further studies regarding the role of the financial sector and VASPs in safeguarding human rights will be crucial for future international security and human rights protection. Further international actions are also encouraged to address these issues by jointly developing human rights-based regulations on international financial services and VASPs for better transparency and trustworthiness.

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