By James Porteous, Research Head, ARF Council on Anti-Illegal Betting & Related Financial Crime
Research assistance by Jeremy Leung, The Hong Kong Jockey Club
Illegal betting, money laundering, organised crime and corruption go hand-in-hand, underlined by recent convictions in Singapore’s biggest-ever money laundering case directly linked to illegal betting syndicates spanning China, the Philippines, Cambodia, Dubai and Europe.
Despite the staggering sums mentioned in the USD 2-billion-dollar case[1] , the illegal betting operations described are in fact completely typical – in many ways, the only notable thing is that in this case, there were successful prosecutions.
On 15 August 2023, Singaporean authorities arrested 10 individuals since jailed for 13 to 16months on money laundering and other charges (see table below). [2]
Illegal betting is the “predicate crime” which generated the money laundered; authorities focused on this crime rather than transnational online illegal betting, because it was easier to prove it had taken place in Singapore as the individuals simply had no way of legitimately explaining their vast wealth. [3] [4]
Nor did they keep a low profile: assets seized included 152 properties, millions in cryptocurrency, gold bars and 62 luxury vehicles such as Ferraris and Rolls-Royces. A treasure trove of high-end watches, 250 luxury handbags, 726 bottles of premium alcohol, jewellery, art collectibles and more was taken from luxury villas in Singapore’s most exclusive residential neighbourhoods,[5] while some of the convicts flaunted their wealth at expensive golf and yacht clubs.[6] [7]
All 10 are from Fujian province in China, but have passports from multiple countries such as Cambodia,Vanuatu, St Kitts & Nevis, Cyprus and Dominica.[8] [9] This highlights the risks associated with so-called citizenship-by-investment schemes which, in essence, grant anyone a passport in exchange for a suitably large cheque, and have been highlighted by global anti-money laundering organisations as key enablers of criminality.[10] [11]
Seventeen other people are wanted by Singapore Police but fled the city, while authorities are also investigating individuals suspected of enabling the laundering by forming shell companies and setting up bank accounts. [12]
Fujian, on China’s south coast, has for hundreds of years seen its people emigrate across Asia and beyond seeking a better life,[23] [24] and several of Asia’s richest people have Fujian origins.[25]
But this entrepreneurial spirit has also inspired highly successful transnational organised crime groups:[26] [27][28] several of the 10 convicts are from a Fujian county, Anxi, labelled by China media as “The Hometown of Fraudsters”,[29] [30][31][32] because many of its citizens are deeply involved in transnational telecom and cyber-scams and illegal betting operations.[33] All of the convicts have long-standing close business and personal relationships, and several are family members. Five have been on various China wanted lists since at least 2015 in relation to illegal betting, telecoms fraud and money laundering [34] .
The illegal betting links go back to at least 2012[35], and the foundation of a betting platform “Hongli International Casino,” (鸿利国际赌博) by a then 23-year-old, Wang Binggang.[36] He was a key target of the Singapore case but evaded authorities, although his cousin was among the 10 convicted.
Wang had been sentenced to three years in jail in 2015 by a Chinese court for his illegal betting operation, but this seems to have had minimal impact on Hongli (or its successor platforms), which were/are based in the Philippines and Cambodia but mainly targeted bettors in Greater China.[37] [38] On his release around 2017/18 (exact date unclear) he moved to Singapore.
Hongli employed a pyramid-scheme style agent-customer recruitment network,[39] used Taiwan-programmed “off the shelf” betting technology, [40] and Macau-themed branding all features common to scores of other illegal betting platforms targeting customers in Asia. (Macau imagery is often used to lend a sheen of legitimacy to such websites by implying they are associated with the city’s famous casinos).
Hongli had business operations initially in a Special Economic Zone in the Philippines, before moving to Bavet, Cambodia. Again, Philippines and Cambodia are typical hubs for such operations. (Border town, Bavet, has become notorious as a hub for online illegal betting and related criminality such as cyber-fraud and human trafficking [41] [42] [43] ,[44] [45] and there is circumstantial evidence suggesting Citibet, the world’s largest illegal betting network specialising in horse racing, may have operations there). [46] [47] [48] [49]
Hongli generated massive profits from illegal betting on sport and casino games – at minimum in the hundreds of millions of dollars a year, according to court records[50] – which were then laundered through multiple offshore accounts and investments in real estate.[51]
All of these characteristics are typical of illegal betting operations in Asia.
It is not known what happened to Hongli’s operations after the imprisonment of Wang in 2015, but indicators are that they simply carried on, probably under a rebrand.
For example, China media has reported that one of the 10 Singapore convicts, Vang Shuiming, has been wanted by China in connection with another online illegal betting platform, “Hengbo Baowang Group” (恒博包网集团). According to one report[52], Vang’s operation had 10,000 employees in the Philippines and Cambodia and was generating the equivalent of USD 687 million a month in turnover.
The numbers seem incredible until one understands the demand in Greater China. For example, one of the largest such operations – that run by Macau junket operator Suncity until the January 2023 imprisonment of its chief Alvin Chau on charges relating to illegal betting, money laundering and organised crime in Macau[53] [54][55][56][57] – had illegal betting turnover reportedly worth ~USD 145 billion a year from Mainland China customers alone. That makes Hongli / Hengbo’s turnover of around ~USD 7-8 billion a year start to seem paltry by comparison.
Details in the conviction of Wang Dehai, who received the longest jail term of the 10 convicted (16 months), underline why Asia’s illegal betting industry will always prove attractive to some.
Wang is the cousin of the founder of the Hongli illegal betting platform and was involved since its inception in 2012, starting as a seemingly lowly tech support officer. He became a customer recruitment agent in 2014 and soon was receiving a 3% share in the platform’s profits. The court heard he earned CNY 80 million (~USD 11 million) in 2016 alone – if that was his 3% cut, by implication Hongli had profits in the region of USD 366 million that year (11 million / 0.03), equating to annual turnover in the billions.
This commission-based profit-sharing model is typical of Asian illegal betting operations. Since the hundreds of online platforms are in most respects indistinguishable from each other, employing similar “plug-in” betting software from the same core suppliers, the key to success is direct recruitment of as many customers to your platform as possible. Customers are in turn incentivised to recruit others in a pyramid-scheme like model.
As shown in Wang’s case, the rewards for successful agents can be extremely lucrative. He forfeited SGD 49 million (USD 36 million) in assets on his conviction, among them a suitcase containing the equivalent of more than USD 1.6 million in cash – authorities were not convinced by his explanation that these were mah-jong winnings.
The Singapore case has ties to jurisdictions across the globe, including Dubai, Cambodia, Malaysia, Philippines, the United Kingdom, Cyprus and Jersey – underlining that, while much of the customer base for illegal betting may be based in Asia, its impacts are felt worldwide.[58] [59]
According to data leaks from Dubai reported by various media outlets, one of the convicts was involved in brokering at least 126 Dubai property sales for money laundering between 2020-2022 worth over AED 537 million (USD 146 million). He himself had bought 30 properties in Dubai.[60] [61]
As noted, the illegal betting platforms involved had operations in both the Philippines and Cambodia, and five of the 10 convicted had Cambodia passports. There do not appear to have been repercussions in Cambodia in relation to the case, perhaps due to vested interests, but in the Philippines, an ongoing corruption scandal has direct links to the Singapore case.
This involves a woman named Alice Guo, mayor of a small town called Bamban, approximately 60 miles away from Metro Manila, within the Clark Freeport and Special Economic Zone – the same SEZ in which the Hongli illegal betting platform had operations. She has been labelled the “POGO mayor” because of apparent close ties to online betting, and public displays of wealth out of keeping with her modest position[62][63] (POGO, Philippines Offshore Gaming Operators, is the local term for the online betting industry). Guo was co-director with two of the Singapore convicts,[64] in a company which built a POGO compound in her town accused of running cyber-scams and forced labour.[65][66] [67] [68][69] She has been suspended pending investigations,[70] with the country’s organised crime commission announcing that “serious and non-bailable” criminal charges will be filed against her and two other officials.[71] At the time of writing in July 2024, she was reportedly “in hiding” from police.
The Singapore case also has geo-political implications, because illegal betting and related organised criminality on China’s borders are a core concern for the country. The arrests came just four days after the visit of Wang Yi, China’s Minister of Foreign Affairs, to Singapore on 10-11 August 2023, although Singapore officials denied there was any link.[72][73]
Wang Yi subsequently hosted senior ministers from Myanmar, Thailand, Cambodia, Laos and Vietnam in Beijing, promising that China and its Asian neighbours would “resolutely combat cross-border crime in the region, especially cyber fraud and gambling.”[74]
In the Philippines, China’s embassy publicly called for a complete shutdown of the POGO online betting industry in June 2024,[75] labelling it a “social ill” detrimental to China-Philippines relations, and in July 2024, the president of the Philippines announced a complete ban on POGOs to be enacted before the end of the year. However, it is highly probable that this will simply drive operators underground (there are many more unlicensed “POGOs” than licensed in the Philippines) and/or see operators move to Cambodia / Laos / Myanmar.
The Singapore convictions underline again the enormous scale and transnational impact of illegal betting – as well as the difficulty of prosecuting it. Notably these convictions were on laundering of the profits from illegal betting, rather than the crime which generated them.
From the outside, the punishments seem relatively slight – most of the 10 served less than a year in jail and have already been deported after time served. It seems probable they might return to “business as usual” elsewhere in Asia – again, this underlines a key message of the ARF Council, that there is little to deter individuals in the face of vast profits to be made from the illegal betting industry.
The case also underlines the reputational impact to jurisdictions such as Singapore which pride themselves as strongly regulated financial hubs of high integrity – although it should be noted that in some other jurisdictions in Asia, this case would never even have come to trial because of corruption.
Ultimately, the Singapore case serves as a stark reminder that illegal betting is far from a victimless crime. Its tentacles reach deep into the fabric of society, fuelling corruption, enabling organised crime, and undermining economic stability. The vast sums involved don't merely represent lost tax revenue; they represent funds diverted from legitimate businesses, communities, and individuals. They fuel human trafficking, exploitation, and addiction. Every dollar laundered through these networks carries with it a human cost.
[1] Mercedes Ruehl, ‘Singapore secures last conviction in $2bn money laundering case’, Financial Times, 7 June 2024 <https://www.ft.com/content/28e9115d-6ab4-4a9a-b57d-defd4968f736accessed on 27 June 2024>
[2] Andrew Wong& Nadine Chua, ‘$3b money laundering case: 10 convicted, 17 on the run;police are after the rest’, The Straits Times, 9 June 2024 <https://www.straitstimes.com/singapore/3b-money-laundering-case-10-convicted-17-on-the-run-police-are-after-the-rest accessed on 16 June 2024>.
[3] David Sun, ‘Suspects in billion-dollar money laundering case in S’pore allegedly linked to China gambling groups’, The Straits Times, 22 August 2023 <https://www.straitstimes.com/singapore/suspects-in-1-billion-money-laundering-case-in-s-pore-allegedly-linked-to-china-gambling-groups accessed on 25 June2024>.
[4] United Nations Office on Drugs and Crime,‘Casinos, Money Laundering, Underground Banking, and Transnational Organized Crime in East and Southeast Asia: A Hidden and Accelerating Threat’, January2024 < https://www.unodc.org/roseap/uploads/documents/Publications/2024/Casino_Underground_Banking_Report_2024.pdfaccessed on 25 June 2024>
[5] Kelly Ng, ‘The $2bn dirty-money case that rocked Singapore’, BBC, 12 April 2024 <https://www.bbc.com/news/world-asia-66840450accessed on 16 June 2024>
[6] Low De Wei & Bernadette Toh, ‘The Banks That Hold Most Money in Singapore Laundering Scandal’, Bloomberg, 8 June 2024< https://www.bloomberg.com/news/articles/2024-06-08/singapore-money-laundering-scandal-what-s-next-for-2-billion-of-seized-assetsaccessed on 26 June 2024>
[7] David Sun & Osmond Chia, ‘Golf club managers to meet over money laundering concerns amid $1 billion probe’, The Straits Times, 29 August 2023 < https://www.straitstimes.com/singapore/golf-club-managers-to-meet-over-money-laundering-concerns-amid-1-billion-probeaccessed on 26 June 2024>
[8] Aidan Jones, ‘Citizenship for sale:Singapore’s US$1.3 billion money laundering probe exposes Chinese criminals’ paid-for passports’, South China Morning Post, 16 September 2023 < https://www.scmp.com/week-asia/economics/article/3234760/citizenship-sale-singapores-u13-billion-money-laundering-probe-exposes-chinese-criminals-paidaccessed on 26 June 2024>
[9] Christine Tan & David Sun, ‘Extradition worries grow for convicted money launderer after deportation to Cambodia’, The Straits Times, 14 May 2024 < https://www.straitstimes.com/singapore/courts-crime/extradition-worries-grow-for-convicted-money-launderer-after-deportation-to-cambodiaaccessed on 25 June 2024>
[10] ‘FATF Report: Misuse of Citizenship and Residency by Investment Programmes’, Financial Action Task Force, November 2023<https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Misuse-CBI-RBI-Programmes.pdf.coredownload.pdfaccessed on 25 June 2024>
[11] ‘FATFREPORT: Money Laundering Through the Physical Transportation of Cash’,Financial Action Task Force, October 2015 <https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/money-laundering-through-transportation-cash.pdf accessed on 16 June 2024>.
[12] Kelly Ng,‘The $2bn dirty-money case that rocked Singapore’, BBC, 12 April 2024 <https://www.bbc.com/news/world-asia-66840450 accessed on 16 June 2024>
[13] Singapore Police Force, ‘First Man Sentenced for Money Laundering Offences in Anti-Money Laundering Probe’, 2 April 2024 < https://www.police.gov.sg/Media-Room/News/20240402_first_man_sentenced_for_money_laundering_offences_in_anti_money_laundering_probe accessed on 2 July 2024>
[14]Singapore Police Force, ‘Man Sentenced for Resisting Arrest and Money Laundering Offences in Anti-Money Laundering Probe’, 4 April 2024 < https://www.police.gov.sg/Media-Room/News/20240404_man_sentenced_for_resisting_arrestaccessed on 2 July 2024>
[15]Singapore Police Force, ‘Third Man Sentenced for Money Laundering Offences In Anti-Money Laundering Probe’, 16 April 2024 < https://www.police.gov.sg/media-room/news/20240416_third_man_sentenced_for_money_laundering_offences_in_anti-money_laundering_probeaccessed on 2 July 2024>
[16]Singapore Police Force, ‘Fourth Man Sentenced for Making False Representations and Money Laundering Offences in Anti-Money Laundering Probe’, 29 April 2024< https://www.police.gov.sg/media-room/news/20240429_fourth_man_sentenced_for_making_false_representionsaccessed on 2 July 2024>
[17]Singapore Police Force, ‘Fifth Man Sentenced for Forgery and Money Laundering Offences in Anti-Money Laundering Probe’, 30 April 2024 < https://www.police.gov.sg/media-room/news/20240430_fifth_man_sentenced_for_forgery_and_money_laundering_offencesaccessed on 2 July 2024>
[18]Singapore Police Force, ‘Sixth Man Sentenced for Forgery and Money Laundering Offences in Anti-Money Laundering Probe’, 14 May 2024 < https://www.police.gov.sg/media-room/news/20240514_sixth_man_sentenced_for_forgery_and_money_launderingaccessed on 2 July 2024>
[19]Singapore Police Force, ‘Seventh Man Sentenced for Forgery and Money Laundering Offences in Anti-Money Laundering Probe’, 23 May 2024 < https://www.police.gov.sg/media-room/news/20240523_seventh_man_sentenced_for_forgery_and_money_laundering_offences_in_antimoneyaccessed on 2 July 2024>
[20]Singapore Police Force, ‘Woman Sentenced for Forgery and Money Laundering Offences in Anti-Money Laundering Probe’, 30 May 2024 < https://www-police-gov-sg.cwp.sg/media-room/news/20240530_woman_sentenced_for_forgery_and_money_laundering_offences_in_antimoney_laundering_probeaccessed on 2 July 2024>
[21]Singapore Police Force, ‘Ninth Person Sentenced for Money Laundering Offences in Anti-Money Laundering Operation’, 7 June 2024 <https://www-police-gov-sg.cwp.sg/media-room/news/20240607_ninth_person_sentenced_for_money_laundering_offences_in_anti_money_laundering_operation%20accessed on 2 July 2024>
[22] Singapore Police Force,‘Tenth Person Sentenced for Forgery and Money Laundering Offences In Anti-Money Laundering Operation’, 10 June 2024 <https://www.police.gov.sg/Media-Room/News/20240610_tenth_person_sentenced_for_forgery_and_money_laundering_offences accessed on 2 July2024>
[23] Loke Kok Kuen Chinese Cultural Legacy Research Trust, ‘Migration of the Hokkien People to Southeast Asia’, 1 April 2023 <https://ccs.city/en/anthology-of-chinese-diasporas/migration-of-the-hokkienaccessed on 27 June 2024>
[24] Management Today, ‘The world's successful diasporas’, 3 April 2007 < https://www.managementtoday.co.uk/worlds-successful-diasporas/article/648273accessed on 27 June 2024>
[25] Iris Gonzales, ‘Fujian, the land of billionaires’, Philstar Global, 6 June 2019 < https://www.philstar.com/business/2019/06/06/1923894/fujian-land-billionairesaccessed on 27 June 2024>
[26] Poh Lay Hoon, ‘Property, nightclubs, collector items: How 'Fujian gang' lifestyles aided money-laundering activities’, Think China, 31 August 2023 <https://www.thinkchina.sg/society/property-nightclubs-collector-items-how-fujian-gang-lifestyles-aided-money-laundering-activitiesaccessed on 27 June 2024>
[27] James O. Finckenauer, ‘Chinese Transnational Organized Crime: The Fuk Ching’, U.S. Department of Justice, 2001 <https://www.ojp.gov/ncjrs/virtual-library/abstracts/chinese-transnational-organized-crime-fuk-chingaccessed on 27 June 2024>
[28] Sebastian Rotella, ‘Outlaw Alliance: How China and Chinese Mafias Overseas Protect Each Other’s Interests’, ProPublica,12 July 2023 <https://www.propublica.org/article/how-beijing-chinese-mafia-europe-protect-interestsaccessed on 27 June 2024>
[29] Mina Chiang, ‘How is Singapore’s largest money laundering case associated with organised cyber fraud?’, LinkedIn Pulse,18 May 2024 < https://www.linkedin.com/pulse/how-singapores-largest-money-laundering-case-organised-mina-chiang-x3vqcaccessed on 25 June 2024>
[30] 徐天,‘盛产铁观音的安溪,为何成了最早搞电诈的“福建口音?’,中国新闻周刊, 21 August 2021 <https://www.inewsweek.cn/society/2021-08-21/13497.shtml?trk=article-ssr-frontend-pulse_little-text-blockaccessed on 25 June 2024>
[31] Sohu.com ‘” 十个安溪九个骗 还有一个在锻炼” 对话安溪电信诈骗犯’,Chongqing Times, 30 August 2016 <https://www.sohu.com/a/112683244_268508?trk=article-ssr-frontend-pulse_little-text-blockaccessed on 25 June 2024>
[32] 中国新闻周刊,‘盛产铁观音的安溪,为何成了最早搞电诈的“福建口音”?’,21 August 2021 <https://www.inewsweek.cn/society/2021-08-21/13497.shtmlaccessed on 28 June 2024>
[33] ElizabethLaw, ‘S’pore’s billion-dollar money laundering case: The criminal link to Fujian’s tea county in China’, Straits Times, 23 August 2024 <https://www.straitstimes.com/asia/east-asia/billion-dollar-money-laundering-case-china-s-tea-county-hides-criminal-side accessed on 16 June 2024>
[34] Ibid.
[35] 8 World, ‘十被告关系错综复杂 洗钱案核心为菲律宾赌博集团’, 24 October 2023 <https://www.8world.com/singapore/billion-dollar-money-laundering-gambling-operation-based-in-the-philippines-2275276accessed on 28 June 2024>
[36] Case No.: (2015) Yuxingchu No. 00176
[37] Christine Tan ‘Founder of Chinese gambling website linked to S’pore’s $2b money laundering case’, The Straits Times, 25September 2023 <https://www.straitstimes.com/singapore/courts-crime/founder-of-chinese-gambling-website-linked-to-singapore-s-2b-money-laundering-case>
[38] David Sun, Andrew Wong & Nadine Chua,‘Wider network of suspects linked to 10 nabbed in billion-dollar money laundering bust’, The Straits Times, 10 September 2023 < https://www.straitstimes.com/singapore/wider-network-of-suspects-linked-to-10-nabbed-in-billion-dollar-money-laundering-bustaccessed on 26 June 2024>
[39] 万事通教育发布,‘新加坡万事通’, Vaster News, 2 November 2023 <http://vasternews.com/index/view/5996.html accessed on 16 June 2024>.
[40] 吴睿明,‘24亿洗钱案 王斌刚王水明或曾注资台公司’, Lianhe Zaobao, 29September 2023 <https://www.zaobao.com/realtime/singapore/story20230929-1438036 accessed on 16 June 2024>.
[41] Khuon Narim,‘Dozens of Vietnamese questioned by police after allegedly seeking escape from Bavet casino’, Camboja News, 21 July 2023 <https://cambojanews.com/dozens-of-vietnamese-questioned-by-police-after-allegedly-seeking-escape-from-bavet-casino/ accessed on 16 June 2024>.
[42] Tith Kognov,‘90% of foreign workers in Bavet casinos illegal’, Khmer Times, 24 January 2023<https://www.khmertimeskh.com/501224586/90-of-foreign-workers-in-bavet-casinos-illegal/ accessed on 16 June 2024>.
[43] Nathan PaulSouthern & Lindsey Kennedy, ‘Laos’ criminal casino empire: Chinese gangsters' new playground’, South China Morning Post, 15 October 2022 <https://www.scmp.com/magazines/post-magazine/long-reads/article/3195932/laos-criminal-casino-empire-chinese-gangsters accessed on 16 June 2024>.
[44] Danielle Keeton-Olsen,’ Inside Southeast Asia’s Casinoland: the ‘underground bank’ at the centre of transnational crime’, South China Morning Post, 20 January 2024 < https://www.scmp.com/week-asia/economics/article/3249121/inside-southeast-asias-casinoland-underground-bank-centre-transnational-crimeaccessed on 27 June 2024>
[45] Inside Asian Gaming, ‘Cambodia to crack down on casinos, illegal gambling as more human trafficking, kidnapping cases emerge’, 19 September 2022 < https://www.asgam.com/index.php/2022/09/19/cambodia-to-crack-down-on-casinos-illegal-gambling-as-more-human-trafficking-kidnapping-cases-emerge/accessed on 27 June 2024>
[46] ‘How Organised Crime Operates Illegal Betting,Cyber Scams & Modern Slavery in Southeast Asia’, Asian Racing Federation,10 October 2023 <https://assets-global.website-files.com/5fbe2bde2b2ef4841cd6639c/651e89accessed on 16 June 2024>.
[47] ‘CasinoBavet-Moc Bai did not respond to allegations of online scam operations’,Business & Human Rights Resource Centre, 3 January 2020 <https://www.business-humanrights.org/en/latest-news/casino-bavet-moc-bai-did-not-respond-to-allegations-of-online-scam-operations/ accessed on 16 June 2024>.
[48] James Porteous, ‘Franchise Wars - How Citibet and Asia’s other biggest bookmakers have McDonaldised illegal betting’, Asian Racing Federation, 6 May 2024 <https://www.asianracing.org/email/202405qb-franchise-wars---how-citibet-and-asias-other-biggest-bookmakers-have-mcdonaldised-illegal-betting accessed on 16 June 2024>.
[49] Andrew Haffner, ‘Taiwan money laundering trials spotlight Asian cyberscam sector’,Nikkei Asia, 3 February 2024 <https://asia.nikkei.com/Spotlight/Society/Crime/Taiwan-money-laundering-trials-spotlight-Asian-cyberscam-sector accessed on 16 June 2024>.
[50] Case No.: (2015) Yuxingchu No. 00176
[51] Christine Tan ‘Founder of Chinese gambling website linked to S’pore’s $2b money laundering case’, The Straits Times, 25 September 2023 <https://www.straitstimes.com/singapore/courts-crime/founder-of-chinese-gambling-website-linked-to-singapore-s-2b-money-laundering-case>
[52] 陀螺财经,‘新加坡百亿洗钱案背后:网诈、赌博,“福建帮”的奢靡与罪恶’,26 September 2023 <https://www.tuoluo.cn/article/detail-10109660.htmlaccessed on 28 June 2024>
[53] Farah Master and Eduardo Baptista, ‘Suncitycloses its Macau VIP gaming rooms after CEO's arrest -sources’, Reuters, 2December 2021 < https://www.reuters.com/markets/europe/shares-macau-gambling-group-suncity-halted-second-time-3-days-2021-12-01/accessed on 26 June 2024>
[54] Emily Hung,‘Macau ‘junket king’ Alvin Chau jailed for 18 years on 162 charges of fraud,illegal gambling and criminal association’, South China Morning Post, 18January 2023 <https://www.scmp.com/news/hong-kong/law-and-crime/article/3207267/macau-junket-king-alvin-chau-jailed-18-years-charges-fraud-illegal-gambling-and-criminal-association accessed on 16 June 2024>.
[55] James Porteous, ‘Back to the Future - Macau Junkets and Illegal Betting’, Asian Racing Federation, 18 August 2023 <https://www.asianracing.org/email/202308qb-back-to-the-future-macau-junkets-and-illegal-betting accessed on 16 June 2024>.
[56] Vivian Chan ‘Suncity’s online gambling operation wagers exceeded $42.2 billion: CCTV’, Asia Gaming Brief, 8 January2024 < https://agbrief.com/intel/deep-dive/08/01/2024/suncitys-online-gambling-wagering-exceeded-42-2-billion/accessed on 25 June 2024>
[57] Radosav Milutinovic ‘Macau’s Syndicate Operated Illegal Cross-Border Gambling to Generate $2.4 Million Profit’, World Casino Directory, 8 January 2024 < https://news.worldcasinodirectory.com/macaus-syndicate-operated-illegal-cross-border-gambling-to-generate-2-4-million-profit-111726accessed on 25 June 2024>
[58] Martin Young & Yan Yan, ‘Members of Alleged Singapore Money Laundering Syndicate Bought London Properties Worth$56M’, Organized Crime and Corruption Reporting Project, 13 September 2023 <https://www.occrp.org/en/investigations/members-of-alleged-singapore-money-laundering-syndicate-bought-london-properties-worth-dollar56maccessed on 27 June 2024>
[59] Samuel Devaraj, ‘Money laundering case:Accused Su Haijin linked to London buildings bought for $73m’, The Straits Times, 14 September 2024 < https://www.straitstimes.com/singapore/courts-crime/money-laundering-case-accused-su-haijin-linked-to-73m-london-buildings-on-famous-shopping-streetaccessed on 27 June 2024>
[60] Andrew Wong,‘3b money laundering case: Su Jianfeng sentenced to 17 months, last of 10 to be sent to jail’, The Straits Times, 13 June 2024 <https://www.straitstimes.com/singapore/courts-crime/3b-money-laundering-case-su-jianfeng-sentenced-to-17-months-last-of-10-to-be-sent-to-jail accessed on 16 June 2024>
[61] David Sun,‘S’pore’s alleged money launderers named alongside terrorist financiers, drug lords in Dubai probe’, The Straits Times, 19 May 2024 <https://www.straitstimes.com/singapore/s-pore-s-alleged-money-launderers-named-alongside-terrorist-financiers-drug-lords-in-dubai-probeaccessed on 16 June 2024>
[62] Cecille Suerte Felipe, ‘Guo declares ₱367 million assets, ₱189 million liabilities’,Philstar Global, 6 June 2024 <https://www.philstar.com/headlines/2024/06/06/2360703/guo-declares-p367-million-assets-p189-million-liabilities accessed on 16 June 2024>
[63] ‘Statement Of Sen. Win Gatchalian On The Suspension Of Bamban Mayor Alice Guo’, Senate of the Philipines, 3 June 2024< http://legacy.senate.gov.ph/press_release/2024/0603_gatchalian2.aspaccessed on 14 June 2024>
[64] Christine Tan, ‘Senate probes Mayor linked to couple in Singapore’s $3b money laundering case’, The Straits Times, 27 May 2024 <https://www.straitstimes.com/singapore/courts-crime/philippine-senate-probes-mayor-linked-to-couple-in-singapore-s-3b-money-laundering-caseaccessed on 16 June 2024>.
[65] Lian Buan& Joann Manabat, ‘Bamban Tarlac raided: POGO fortress Alice Guo’, Rappler,30 May 2024 <https://rappler.com/newsbreak/in-depth/bamban-tarlac-raided-pogo-fortress-alice-guo/ accessed on 16 June 2024>.
[66] Dempsey Reyes & Frances Mangosing, ‘POGO probe: Guo, 2 other Bamban execs suspended’, Inquirer.Net, 4 June 2024 <https://newsinfo.inquirer.net/1947791/pogo-probe-guo-2-other-bamban-execs-suspended accessed on 16 June 2024>.
[67] Alan Robles,‘Chinese asset in Philippines raises alarm over mystery mayor suspected links to POGOs’, South China Morning Post, 16 May 2024 <https://www.scmp.com/week-asia/politics/article/3262875/chinese-asset-philippines-raises-alarm-over-mystery-mayor-suspected-links-pogos accessed on 16 June 2024>.
[68] Neil Jayson Servallos, ‘Ombudsman suspends Mayor Guo, 2 others’, Philstar Global, 4 June2024 <https://www.philstar.com/headlines/2024/06/04/2360188/ombudsman-suspends-mayor-guo-2-others accessed on 16 June 2024>.
[69] Ibid.
[70] Andrew Wong & Nadine Chua, ‘$3b money laundering case: 10 convicted, 17 on the run; police are after the rest’,Straits Times, 9 June 2024 <https://www.straitstimes.com/singapore/3b-money-laundering-case-10-convicted-17-on-the-run-police-are-after-the-restaccessed on 16 June 2024>.
[71] Frank Schuengel, ‘Criminal charges to be filed against Philippines POGO Mayor Alice Guo’, Asian Gaming Brief, 17 June 2024< https://agbrief.com/news/philippines/17/06/2024/criminal-charges-to-be-filed-against-philippines-pogo-mayor-alice-guo/accessed on 16 June 2024>.
[72] Grace Leong, ‘Money laundering probe sparked by suspicious transaction reports, not external pressure: Shanmugam’, The Straits Times, 11 September 2023 < https://www.straitstimes.com/business/money-laundering-probe-sparked-by-suspicious-transaction-reports-not-external-pressure-shanmugamaccessed on 26 June 2024>.
[73] Kimberly Lin, ‘Singapore money-laundering probe not done ‘at the behest of China’: minister’, South China Morning Post, 3Octo.ber 2023 < https://www.scmp.com/week-asia/politics/article/3236672/singapore-money-laundering-probe-not-done-behest-china-ministeraccessed on 26 June 2024>.
[74] Zhao Ziwen, ‘China vows closer security ties with Mekong states as cyber scams, Myanmar unrest have cross-border impact’,South China Morning Post, 8 December 2023 <https://www.scmp.com/news/china/diplomacy/article/3244388/china-vows-closer-security-ties-mekong-states-cyber-scams-myanmar-unrest-have-cross-border-impactaccessed on 28 June 2024>
[75] Embassy of the People's Republic of China in the Republic of the Philippines, ‘Statement of the Spokesperson of the Chinese Embassy in the Philippines’, Embassy of the People's Republic of China in the Republic of the Philippines, (14 June 2024),http://ph.china-embassy.gov.cn/eng/sgdt/202406/t20240614_11436131.htm, accessed3 July 2024.
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