Key Findings of the Enforcement Action

1. The Transnational Criminal Organization (TCO)

The Prince Holding Group, despite presenting itself as a major Cambodian conglomerate focused on real estate, financial services (including Prince Bank), and consumer services , was allegedly controlled by Chen Zhi and secretly operated as one of "Asia's largest transnational criminal organizations" . Prosecutors allege the scheme was operational from 2015 to the present.  

2. Forced Labor and Fraud

Operation Scale: The core business involved sophisticated, high-volume cryptocurrency investment fraud schemes, commonly known as "pig butchering" (Sha Zhu Pan) . Chen Zhi reportedly boasted that this scam operation was generating up to $30 million per day in illicit profits .

Human Cost: The TCO constructed and ran vast, guarded scam compounds across Cambodia, Laos, and Myanmar where thousands of migrant workers were trafficked and held against their will . These workers were subjected to systemic violence, beatings, and electrocution to ensure compliance and efficiency in executing the scams .

3. Record-Breaking Seizure and Sanctions

The operation was executed with a coordinated, multi-pronged legal strategy:

Criminal Charges: The U.S. Department of Justice (DOJ) unsealed an indictment charging Chen Zhi, a UK and Cambodian national, with wire fraud conspiracy and money laundering conspiracy. If convicted, he faces a maximum of 40 years in prison .

Asset Forfeiture: The DOJ successfully filed a civil forfeiture complaint against approximately 127,271 Bitcoin, valued at roughly $15 billion at the time of the action. This is officially the largest civil forfeiture action in the history of the Department of Justice.  

Financial Isolation: The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued sweeping sanctions, designating 146 individuals and entities, including Prince Holding Group and Prince Bank Plc. . Concurrently, the Financial Crimes Enforcement Network (FinCEN) designated the Huione Group as a primary money-laundering concern, severing its access to the U.S. financial system.  

UK Action: Parallel actions by the U.K. imposed asset freezes and travel bans, seizing high-value assets used for laundering, including a £12 million North London mansion .

4. Forensic and Geopolitical Challenges

Bitcoin Tracing: Forensic analysis revealed the $15 billion in Bitcoin was held across 25 unhosted wallets and had remained largely dormant since December 2020. Investigators successfully secured the private keys, demonstrating that large decentralized crypto holdings are not impervious to state seizure.  

Fugitive Status: Chen Zhi is believed to be at large in Cambodia . His apprehension is complicated by allegations that he authorized bribes to foreign officials to evade law enforcement and the absence of a formal extradition treaty between the United States and Cambodia. The coordinated sanctions serve as a form of "financial extradition," neutralizing his influence and financial infrastructure .  

This action sets a powerful precedent, establishing an integrated enforcement model to target TCOs that leverage state corruption, human rights abuses, and digital asset markets for massive financial gain.