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On October 15, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a final rule under Section 311 of the USA PATRIOT Act that prohibits U.S. financial institutions from conducting business with the Cambodia-based Huione Group, a financial services conglomerate based in Phnom Penh, Cambodia. Huione Group is the parent company of, or otherwise controls, several subsidiaries, affiliates, and components, including, but not limited to: Haowang Guarantee, Huione Pay PLC, and Huione Crypto. The rule targets all these entities as Huione Group for laundering proceeds of virtual currency scams on behalf of malicious cyber actors, among other criminal wrongdoing. The final rule can be found here: https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-severing-huione-group-us-financial-system.
In addition, the Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed sweeping sanctions on 146 targets within the Prince Group Transnational Criminal Organization (Prince Group TCO), a Cambodia-based network led by Cambodian national Chen Zhi that operates a transnational criminal enterprise through online investment scams targeting Americans and others worldwide. Prince Group TCO is composed of Cambodia-based Prince Holding Group, Chen Zhi, his close associates and business partners, and their core commercial interests, all of which operate in furtherance of Prince Group TCO's criminal enterprise. Treasury's news release can be found here: https://home.treasury.gov/news/press-releases/sb0278.
FinCEN's Key Findings and Final Rule
FinCEN found that Huione Group is a foreign financial institution of primary money laundering concern, and its final rule imposes a prohibition on covered financial institutions from opening or maintaining a correspondent account for, or on behalf of, Huione Group.
- Prohibition: Covered financial institutions are prohibited from opening or maintaining correspondent accounts for, or on behalf of, the Huione Group. Such institutions much take reasonable steps to not process a transaction for the correspondent account of a foreign banking institution in the United States if that transaction involves Huione Group.
- Enhanced Due Diligence: Covered financial institutions must employ special due diligence to all foreign correspondent accounts to prevent those accounts being used to process transactions involving Huione Group and provide notice to such account holders regarding these prohibitions.
- Effective date: The final rule is effective November 17, 2025.
Detailed Grounds for Action
Huione Group served as a crucial hub for laundering billions of dollars from a variety of illegal activities. These activities include:
- North Korean cybercrimes: Laundering proceeds from cybercrimes carried out by the Democratic People's Republic of Korea (DPRK), including the Lazarus Group.
- Transnational fraud: Processing hundreds of millions of dollars in illicit proceeds from transnational criminal organizations, particularly those in Southeast Asia.
- "Pig butchering" scams: Laundering funds from virtual currency investment scams that targeting individuals across the world.
- Online marketplace for crime: Operating an online marketplace that offered illegal financial services and tools for trafficking.
Huione Group combined its substantial participation in worldwide criminality with an absence of, or a highly ineffective, anti-money laundering program, along with recent changes that served to further obscure Huione Group's involvement in illicit activity.
Broader United States Government Activity
The FinCEN rule is part of a broader, coordinated enforcement action by United States and United Kingdom authorities to combat large-scale criminal networks operating in Southeast Asia.
- Prince Group sanctions: OFAC and the U.K. Foreign, Commonwealth, and Development Office announced sanctions against the Cambodia-based Prince Group, which is accused of running a criminal empire through online investment scams and scam compounds that rely on human trafficking and forced labor.
- Criminal charges: The United States Attorney's Office in the Eastern District of New York unsealed an indictment against Chen Zhi, the founder of the Prince Group, on charges of wire fraud and money laundering conspiracy. The Department of Justice's press release on the indictment can be found here: https://www.justice.gov/opa/pr/chairman-prince-group-indicted-operating-cambodian-forced-labor-scam-compounds-engaged.
- Largest-ever bitcoin seizure: As part of the action, the Department of Justice seized approximately $15 billion in bitcoin, alleged proceeds of Chen Zhi's fraud schemes.
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