Special Edition with Guest Student Authors from the Schar School of Policy and Government at George Mason University (https://traccc.gmu.edu/)

I have been honored to be an Adjunct Professor at GMU’s TraCCC (The Terrorism, Transnational Crime and Corruption Center) for several years. Many AML/Sanctions experts have joined me as guest lecturers as we work with graduate students either in or contemplating a career in our community. This past summer, in my International Money Laundering, Corruption, and Terrorism class, the challenge was to educate and stay current with the plethora of changes occurring in the US and internationally.

The students were required to submit a final paper on a topic related to the vast areas covered in class, and I have selected several papers that I know will be of interest to many.

John Byrne

Chair, AML RightSource Advisory Board

Abstract

This paper examines how scam economies in Cambodia, Myanmar, and Laos have developed into systems driven by human trafficking, online fraud, and crypto money laundering. These activities are protected by elite political networks. At the center is the Huione Group, a financial platform that has processed over 100 billion dollars in Tether (USDT) transactions and provided services ranging from fake IDs to forced labor. Current enforcement approaches are ineffective. The Financial Action Task Force (FATF) depends on reputational pressure and voluntary compliance, which are ineffective when states profit from criminal operations. The paper argues for shifting from symbolic pressure to cutting access when governments refuse to act against the scam economy. This paper proposes using targeted sanctions under Executive Orders and pushing global de-risking from jurisdictions that host criminal economies. Special attention is given to sanctioning Politically Exposed Persons who move illicit funds through U.S.-linked assets.

I. Introduction: Southeast Asia’s Scam Economy and Global Consequences

Southeast Asia is now the center of one of the most dangerous and fast-growing criminal economies in the world. According to the United Nations Office on Drugs and Crime, cyber fraud in East and Southeast Asia caused between 18 and 37 billion dollars in global losses in 2023, with much of it traced to Cambodia, Myanmar, and Laos (UNODC, 2024). These three countries now generate about 43.8 billion dollars each year from criminal operations, almost 40 percent of their combined GDP (USIP, 2024). In Cambodia alone, scam activity brings in around 12.5 billion dollars per year—more than half the country’s formal economy.

This is not just a regional problem. These scams reach across borders, using social media, fake apps, and cryptocurrency to target victims in over 50 countries. At least 120,000 people are trapped in scam compounds in Myanmar, and another 100,000 in Cambodia (OHCHR, 2023). Most are multilingual, educated, and trafficked from places like Taiwan, India, and Africa (IOM, 2024). Cambodia now hosts over 50 large scam compounds, and over 80% of the world’s total are in this region (Global Initiative, 2024). The Financial Crimes Enforcement Network found that Cambodia’s Huione Group laundered over 4 billion dollars since 2021, including money from North Korean cyberattacks and crypto fraud (FinCEN, 2025). Governments in this region are not stopping it. Amnesty International reports that Cambodian authorities ignored 33 scam compounds even after being warned (Amnesty International, 2023). In Myanmar, military-aligned forces are profiting directly from scam operations (US Treasury, 2023). Criminal groups are also using artificial intelligence, deepfakes, and underground banking to stay ahead of law enforcement (UNODC, 2024). The Huione Group even offers full criminal services, from laundering to illegal payments (FinCEN, 2025).

This paper asks three main questions. First, what does the scam economy actually look like—from the structure of the criminal networks to the digital tools and trafficking pipelines they use? Second, how deeply are state actors involved, and how have countries like Cambodia, Myanmar, and Laos become safe havens for transnational crime? Third, why has the global anti-money laundering system failed, and what would it take to shift from reactive to proactive enforcement?

II. Inside the Scam State Economy: Huione, Blockchain Laundering, and Trafficking

Huione Group operates as a central platform for laundering, financing, and scaling scam compound operations across Southeast Asia. Its payments division processed more than 100 billion dollars in Tether (USDT) transactions between January 2024 and June 2025, including 54.5 billion dollars in deposits and 57.2 billion dollars in withdrawals, primarily through the Tron blockchain (PANewsCN, 2025). These volumes suggest deliberate capital cycling to conceal criminal proceeds. Huione Guarantee, a Telegram-based marketplace later rebranded, facilitated at least 24 billion dollars in illicit transactions, including forged documents, SIM cards, trafficked labor, and scam infrastructure (Elliptic, 2025).

Huione’s brokerage arm routed over 4 billion dollars in criminal proceeds between August 2021 and January 2025, including 37 million dollars from North Korean cyber heists and 36 million from pig-butchering scams (FinCEN, 2025). After affiliated Tether wallets were frozen, the group launched its own stablecoin, USDH, marketed as immune to future freezes and hosted on a proprietary blockchain (SlowMist via Binance Square, 2025). Laundered funds moved through Cambodian casinos and real estate firms tied to politically exposed persons (Crowdfund Insider, 2025).

A forensic trace found 10.3 billion dollars in new Tether (USDT) entering Huione- linked wallets within 48 days of the FinCEN action, with nearly 943 million dollars routed to major exchanges (Cointelegraph, 2025). UN research reported a 600 percent spike in criminal deepfake usage in early 2024, confirming that compounds are adopting generative AI tools at scale (UNODC, 2025). Border compounds now rely on satellite tools to stay online during raids; Thai police intercepted 38 Starlink dishes between March and April (The Record, 2025). Even after Telegram bans, Huione-affiliated markets reappear with minimal delay, migrating users to backup channels (Elliptic, 2025).

Trafficking fuels this system. More than 300,000 people are held in scam compounds across the region. They are multilingual, digitally skilled, and forced to work 15 to 17 hours daily under threat of violence (INTERPOL, 2025). Victims originate from at least 66 countries, showing the global scale of labor supply (Deutsche Welle, 2025). Phone data links scam parks like Shwe Kokko directly to Myanmar’s military centers, confirming collusion between criminal sites and state actors (Business & Human Rights Resource Centre, 2025).

Illicit funds also move across borders. Investigators traced stolen assets from Bybit and Poloniex hacks into Huione wallets, which routed them through OTC brokers in Laos and Indonesia (TRM Labs, 2025). Some compounds specialize in recruitment, others in scam operations, and others in laundering. UNODC and GI-TOC report that this modular structure allows continuous operations, even under pressure (UNODC, 2025). The full network—spanning money, people, and data—is regionally integrated, politically protected, and financially scalable.

III. The Scam-State Nexus: Political Elites, Corruption, and the Golden

The scam economy in Southeast Asia is directly tied to government elites. In Cambodia, the Huione Group processed more than one hundred billion dollars in Tether(USDT) through its payment rails in just 18 months. Its directors include relatives of Prime Minister Hun Manet and key business allies, but there is no serious oversight or investigation (Crowdfund Insider, 2025). Its Huione Guarantee platform alone enabled at least twenty-four billion dollars in transactions for SIM cards, fake IDs, and human trafficking services (Elliptic, 2025). Even after U.S. sanctions, wallets linked to Huione pushed nearly one billion dollars into major exchanges, proving the system remains active and protected (Cointelegraph, 2025).

In Myanmar, the Karen Border Guard Force earns around one hundred ninety-two million dollars each year from leasing land and providing security to scam compounds like Shwe Kokko and KK scam park (Justice for Myanmar, 2025). These sites continue to expand. Despite claims of crackdown, recent reports confirm compounds relocated to Laos and Cambodia instead of being shut down (DVB, 2025). The scam system is mobile, but its backers remain constant: the Myanmar military and its allied militias.

In Laos, Zhao Wei—sanctioned for human trafficking and drug crimes—continues to operate the Golden Triangle Special Economic Zone with full political support. In December 2024, Lao authorities gave him a national medal for development contributions (The Diplomat, 2024). Even after that, scam operators were given a government deadline to move out, not arrested or prosecuted, and many continued business as usual (The Diplomat, 2024). The danger is not just corruption—it is structural protection. These governments give criminals land, licenses, and legal shelter. In Cambodia alone, at least fifty-three scam compounds are known to exist, yet authorities have failed to intervene, even with proof of slavery and torture (CyberScoop, 2025). Scam networks are sustained by political connections, not despite them. As long as these alliances hold, no financial or human rights regulation will work—especially when reputational enforcement becomes the only tool left.

IV. When Reputation Fails: FATF, Blacklists, and the Scam State Loophole

The global anti-money laundering system is not built to stop states that profit from crime. It assumes that governments want to fight financial wrongdoing. But in Cambodia, Myanmar, and Laos, the state is part of the scam economy. These governments protect money laundering, trafficking, and cyber scams. They are not victims of corruption. They are the beneficiaries.

The Financial Action Task Force (FATF) is not equipped to manage this challenge. It is not an enforcement body. It gives advice, publishes lists, and hopes countries comply. But scam states do not care about advice. They care about revenue. FATF calls itself a “policy-making body,” not a regulator. Its standards are soft law. There is no court to enforce them. Countries can ignore the rules without consequence (Pucci, 2023). That works only when governments care about reputation. Scam states do not. Even the internal structure of the Financial Action Task Force (FATF) reflects its limitations. The Secretariat, based at the Organisation for Economic Co-operation and Development (OECD) headquarters in Paris, has only 71 staff overseeing more than 200 jurisdictions. Seventy-two percent of its €12.9 million budget is allocated to salaries (AML Intelligence, 2023). This leaves little capacity for in-depth investigations or consistent oversight. Countries are largely responsible for drafting their own evaluations, with limited external verification. As a result, jurisdictions can project compliance while enforcement remains weak. In fact, 76 percent of countries are rated as compliant on paper, even as practical implementation often falls short (FATF, 2023). Former Executive Secretary David Lewis called the Financial Action Task Force (FATF) a group of “mid-level bureaucrats” unable to handle the scale of global crime (ACAMS Moneylaundering.com, 2022). He said most staff are in their roles for one or two years and lack institutional memory. He resigned because he saw no way forward.

The problem was not just resourcing, but structure. The consensus model means two or three countries can block action. The result is paralysis.

Authoritarian states now use anti-money laundering (AML) to control society. They freeze nonprofit accounts, arrest critics, and monitor activists under the pretext of financial integrity. At the same time, they let politically connected firms move billions through unregulated channels (RUSI, 2022). Financial Action Task Force (FATF)’s tools are being turned into weapons.

Academic research highlights the deep inefficiencies in the global anti-money laundering (AML) system. Despite massive compliance spending by banks, taxpayers, and businesses, less than 0.1 percent of criminal proceeds are ever recovered. This suggests a striking mismatch between cost and outcome. One study found that the global AML regime costs more than 100 times what it recovers, calling it “the world’s least effective policy experiment” (Pol, 2022).

The blacklist remains limited. It includes only North Korea, Iran, and Myanmar. Cambodia was taken off the greylist in 2023—even as scam activity expanded (Basel Institute on Governance, 2023). The list projecting a sense of pressure without delivering meaningful consequences.

This is why states engaged in large-scale fraud continue to thrive. They understand that the Financial Action Task Force (FATF) lacks direct enforcement authority and has no formal mechanisms to compel compliance. FATF issues valuable guidance, but it cannot impose penalties or ensure implementation. Over time, these regimes have learned that signaling superficial cooperation is often enough to avoid serious consequences and maintain access to global financial systems. The difference between how things look and how they are enforced shows a bigger problem. Without stronger pressure, serious crime keeps going.

V. Real Pressure for Real Crime: Enforcement-Driven Isolation of Scam States

Reputation-based pressure breaks down when crime is backed by the state. Scam states like Cambodia, Myanmar, and Laos are not ashamed of laundering billions; they profit from That’s why financial enforcement must go beyond warnings. It must lead to actual disconnection from the global financial system. The United States has already shown what works.

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) action under Section 311 of the USA PATRIOT Act—formally titled “Special Measures for Jurisdictions, Financial Institutions, or International Transactions of Primary Money Laundering Concern”—against the Huione Group set the right precedent. By labeling Huione a primary money laundering concern, Treasury prohibited all U.S. financial institutions from opening or maintaining correspondent or payable-through accounts, effectively cutting the network off from the U.S. financial system (FinCEN, 2025). That action targeted more than $4 billion in laundered funds, including illicit flows from cyber scams and North Korean-linked heists (Elliptic, 2025).

Sanctions under Executive Order 13581, “Blocking Property of Transnational Criminal Organizations,” and the Global Magnitsky Human Rights Accountability Act, which targets perpetrators of serious human rights abuse and corruption, have also proven highly effective. In 2023, the United States sanctioned Cambodian tycoon Ly Yong Phat and his L.Y.P. Group for exploiting trafficked labor at scam centers (Radio Free Asia, 2023). The same year, Office of Foreign Assets Control (OFAC) sanctioned Myanmar militia leader Saw Chit Thu and the Karen National Army for running scam compounds and smuggling operations tied to cross-border cybercrime (The Diplomat, 2025).

The Financial Action Task Force’s blacklisting of Myanmar in 2022 demonstrated how even non-binding international standards can produce serious, real-world consequences. Global banks began to cut ties, not because of enforcement, but because the risk was too high to maintain exposure—a pattern of systemic de-risking that functioned as real-world isolation (Tilleke & Gibbins, 2025).

Meanwhile, U.S. intelligence coordination is evolving. The Anti-Money Laundering Act of 2020 modernized existing frameworks by allowing banks to more freely share Suspicious Activity Reports with foreign affiliates, a shift intended to help identify high-risk actors in real time (FinCEN, 2022). FinCEN guidance also emphasizes rapid reporting on laundering, trafficking, and crypto fraud, especially involving designated individuals or jurisdictions (Guidehouse, 2022). The solution is clear: expand the use of actions under Section 311 of the USA PATRIOT Act, escalate sanctions against political elites, mandate coordination on Suspicious Activity Reports (SARs), and trigger international de-risking. The Financial Action Task Force (FATF) must move beyond issuing polite warnings and instead link blacklisting to concrete financial cutoffs. When governments are the ones running the illicit schemes, financial isolation is not optional—it is the only effective response.

VI. Conclusion: From Lost Money to Lost Lives

“Bad things always have global spillover, but good things never do.” In 2023, a 24-year-old man from India was deceived into traveling to Myanmar with the promise of a tech job. Instead, he was forced into a scam compound. He told journalists that he was beaten with metal rods, electrocuted, and held for months until his family paid nearly twenty thousand dollars to get him out. He said, “I thought I was going to die there” (Deutsche Welle, 2025). An elderly woman from Germany lost her entire life savings to a fake crypto romance. She told the press, “It wasn’t just the money—it was ten years of my life” (Münchener Post, 2025). These are not rare stories. They are the cost of letting scam states thrive.

This is what anti-money laundering is supposed to stop. Not just shell companies or crypto flows—but the criminal systems that trap people, steal lives, and run on financial networks the world still lets operate. Southeast Asia has become the center of global scam economies, and the longer we wait, the more this model spreads. If banks, governments, and Anti-Money Laundering watchdogs do not act with real pressure, then the next victim’s family will not be able to pay. The international Anti-Money Laundering community must stop pretending that soft diplomacy and reputational nudges are enough. Real enforcement means disconnection, not dialogue. Otherwise, the model will spread faster than any response can catch up.

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