A recent announcement from the United States Department of Justice (DOJ) draws an alarming connection between human trafficking, forced labor and large‐scale cryptocurrency fraud. On October 14, 2025, the DOJ unsealed an indictment that charges Chen Zhi (aka “Vincent”), founder and chairman of the conglomerate Prince Holding Group (“Prince Group”), with orchestrating a transnational crime enterprise that combined forced‐labor camps in Cambodia with global “pig butchering” style crypto investment scams. 

What’s at play

• Since about 2015, Chen Zhi directed the Prince Group, which operated dozens of business entities in over 30 countries—including real estate, financial services and consumer services—but secretly built one of Asia’s largest transnational criminal organizations. 

• The scheme involved “compounds” in Cambodia: workers trafficked, confined behind barbed-wire fences and dormitories, forced to carry out fraudulent investment schemes targeting victims globally (including in the U.S.). 

• The fraud method: victims were contacted via social media or messaging apps, enticed into transferring cryptocurrency with promises of profits; funds were stolen, laundered, and redistributed into sophisticated schemes. 

• Criminal proceeds: the DOJ filed a civil forfeiture complaint for approximately 127,271 Bitcoin (worth roughly $15 billion), stored in unhosted wallets whose private keys the defendant held. This is the largest forfeiture action in DOJ history. 

• Laundering techniques included “spraying” and “funneling” transactions across many virtual addresses, consolidation, conversion to fiat, use of traditional bank accounts, online gambling and crypto-mining companies. 

• Additional layers: bribery of public officials, political influence abroad, systemic use of forced labor, and violence against workers inside the compounds. 

Why this matters for fraud professionals and CFEs

• Intersection of human trafficking & financial crime: This case underscores how fraud examination isn’t just about numbers—entire schemes hinge on exploitation of vulnerable people. CFEs must be alert to red flags that cross over into forced labor or human‐trafficking domains.

• Cryptocurrency risk landscape: The use of crypto in large-scale laundering here demonstrates how emerging technologies become enablers of fraud and money laundering. Knowing how crypto flows work, what “unhosted wallets” are, and how layering via many addresses occurs is increasingly relevant.

• Global & cross‐border enforcement: The case spans multiple countries, uses assets held offshore, and involves coordinated action across agencies (FBI, DEA, DOJ, etc.). That reminder: fraud schemes today operate transnationally and require coordination and international awareness.

• Asset recovery potential: The massive forfeiture shows that when a scheme is disrupted effectively, there is real potential for recovery of stolen assets—something investigators and compliance teams can use to bolster deterrence and remediation messaging.

• Victim focus: Beyond financial loss, the human cost—workers forced to commit crimes under threat—is substantial. For fraud examiners working in compliance, audit, investigations, remediation, the human dimension should elevate the urgency of strong controls, reporting and internal/external oversight.

Key take-aways for your team or organization

• Review your organization’s crypto‐asset exposure: Do you accept or process crypto assets? Are there controls for unhosted wallets, layering risks, or tracing inbound/outbound crypto flows?

• Increase awareness of forced‐labor red flags in vendor/supplier chains: Are there remote call centres, dormitory-style housing, high turnover, unusual recruitment practices, or workers relocated internationally who could be exploited for fraud operations?

• Reinforce cross-department collaboration: Fraud risk may live in compliance, cyber, human resources, procurement, vendor management. Ensure your investigation protocols consider human trafficking, cyber‐fraud and financial crime jointly.

• Update training for investigators/examiners on crypto laundering schemes: Understand “spraying” and “funneling,” unhosted wallets, layering of virtual currencies, and linkages to traditional business front operations.

• Document and publicize asset recovery success stories: Use cases such as this to show that fraud schemes can lead to sizable forfeitures—helping build organizational buy-in for investment in preventive controls and incident response.

Next steps for CFEs & the ACFE PNW community

This story offers a rich case study for our chapter’s continuing education and blog content. I encourage you to:

1. Bring this case into your next team briefing or fraud-risk committee meeting.

2. Use it as a scenario in a table-top exercise or training session for your fraud investigations team.

3. Monitor upcoming ACFE PNW webinars or Lunch & Learns that may cover crypto asset fraud, forced-labor risks, or transnational schemes—consider whether your organization will host a discussion or partner event.

4. Connect with peers in the ACFE PNW network to share lessons learned from your own crypto exposures, vendor management practices, or human‐trafficking diligence.