Case Overview: When Compliance Works — How a Source of Funds Check Uncovered a Crypto Laundering Scheme Worth More than £5 Billion

The case of Zhimin Qian, who orchestrated a RMB 43 billion Ponzi-style investment fraud in mainland China, demonstrates the critical importance of robust due diligence and verification controls. Between 2014 and 2017, Qian deceived over 128,000 investors before converting illicit proceeds into Bitcoin and relocating abroad under falsified documents.

Attempting to legitimise her crypto-derived wealth through luxury property purchases, Qian’s laundering network went undetected until her associate failed a Source of Funds (SOF) check during a £35 million property transaction. This failure triggered further scrutiny, leading to the exposure of one of the world’s largest cryptocurrency-related laundering schemes, worth £5 billion.

The incident underscores a key lesson: effective KYC, Source of Funds, and Enhanced Due Diligence processes are not just regulatory requirements—they are essential safeguards that prevent financial crime, protect institutional integrity, and uphold public trust.

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