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{"actor":"system:backfill","investigation_id":"bf324913-fcd5-4c45-9393-1b2ebd419eac","kind":"publish","page_slug":"h-pay-service-plc-huione-successor-entity","published_at":"2026-06-26T12:29:56.540Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"H-Pay Service PLC (Huione Successor Entity)","sections":[{"content":"On June 23, 2026, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to amend its October 2025 Huione Group Final Rule to explicitly include H-Pay Service PLC and any successor entity. The proposed rule defines 'successor entity' as any person that replaces Huione Group by acquiring its assets in whole or in part and/or carrying out its affairs under a different name. The NPRM was published in the Federal Register on June 25, 2026 (document 2026-12794). The October 2025 final rule had already imposed two special measures on Huione Group under Section 311 of the USA PATRIOT Act: a prohibition on U.S. covered financial institutions opening or maintaining correspondent accounts for Huione Group, and a requirement to take reasonable steps not to process transactions involving Huione Group through correspondent accounts. FinCEN's stated rationale for the June 2026 extension was to 'guard against Huione Group's attempts to circumvent being cut off from the U.S. financial system.' The U.K.'s Foreign, Commonwealth and Development Office and Treasury's Office of Foreign Assets Control took complementary enforcement actions alongside the October 2025 final rule.","heading":"Regulatory Designation and Proposed Rule Extension","severity":"critical","sources":[{"credibility":1,"name":"FinCEN: Proposes to Sever H-Pay Service PLC and Other Huione Group Successor Entities from the U.S. Financial System","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-proposes-sever-h-pay-service-plc-and-other-huione-group-successor"},{"credibility":1,"name":"Federal Register: Definition of Huione Group, Primary Money Laundering Concern (2026-12794)","type":"regulatory","url":"https://www.federalregister.gov/documents/2026/06/25/2026-12794/definition-of-huione-group-a-financial-institution-operating-outside-the-united-states-of-primary"},{"credibility":1,"name":"FinCEN: Issues Final Rule Severing Huione Group from the U.S. Financial System (October 2025)","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-severing-huione-group-us-financial-system"},{"credibility":1,"name":"Treasury: Further Dismantles Overseas Scam Operations Targeting Americans","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0538"}]},{"content":"On June 24, 2026, the U.S. Department of Justice announced the seizure of a cloud computing account used by subsidiaries of the Huione Group. The account hosted backend infrastructure that allegedly enabled criminals to transfer, move, and conceal billions of dollars in fraud proceeds before converting funds into the banking system. The seizure was conducted by the FBI's San Francisco Field Office and IRS Criminal Investigation, with analytical support from blockchain analytics firms Chainalysis and Elliptic, as well as Google's cybercrime team. Assistant Attorney General A. Tysen Duva stated: 'Today's seizure strikes a blow against one of the world's most prolific criminal marketplaces.' U.S. Attorney Craig H. Missakian added: 'We will not allow individuals or companies to exploit our country's technology to defraud hardworking Americans.' The seized infrastructure supported Huione Guarantee (also known as Haowang Guarantee), a Telegram-based marketplace where vendors traded stolen payment card data, identity information, malware, and money laundering services.","heading":"DOJ Infrastructure Seizure (June 2026)","severity":"critical","sources":[{"credibility":1,"name":"DOJ: Justice Department Seizes Backend Infrastructure Used by the Huione Group for Money Laundering Services","type":"regulatory","url":"https://www.justice.gov/opa/pr/justice-department-seizes-backend-infrastructure-used-huione-group-money-laundering-services"},{"credibility":2,"name":"Decrypt: DOJ Seizes Huione Infrastructure Linked to Billions in Crypto Laundering","type":"news_article","url":"https://decrypt.co/371950/doj-seizes-huione-infrastructure-linked-to-billions-in-crypto-laundering"},{"credibility":2,"name":"Yahoo Finance: DOJ Seizes Huione Infrastructure Linked to Billions in Crypto Laundering","type":"news_article","url":"https://finance.yahoo.com/markets/crypto/articles/doj-seizes-huione-infrastructure-linked-114927633.html"}]},{"content":"H-Pay Service PLC was incorporated in October 2024 according to Cambodia's business registry, shortly after Huione Pay lost its Cambodian payment services license. FinCEN and investigative reporting allege that H-Pay inherited Huione Pay's branches, customer base, branding elements, and operational footprint. Reporting by CamboJA News documented H-Pay signage replacing Huione Pay branding at multiple locations following regulatory actions against the original entity. H-Pay's headquarters occupy the same building as a Panda Bank branch. Three individuals are listed as H-Pay directors — Hung Kheang, Sim Sotheary, and Rath Sovannarong (chairman) — all of whom denied knowledge of or involvement with the firm when contacted by reporters. Hung Kheang is identified in Panda Bank's 2024 annual report as chief credit officer of that institution. Historical Huione-Panda Bank ties include He Yanming (listed Huione Crypto owner) serving as a Panda Bank director, while Hun To and Li Xiong — both former Huione business directors — resigned from Panda's board in October 2024. By March 2026, H-Pay's own Cambodian license had been revoked. Approximately 1,300 Huione Pay customers who were locked out of their accounts submitted identification and claims to the National Bank of Cambodia in December 2025, with protests reported turning violent.","heading":"H-Pay as Huione Pay Successor: Corporate Structure and Evasion Allegations","severity":"critical","sources":[{"credibility":2,"name":"CamboJA News: H-Pay Emerges From Sanctioned Huione Pay, Panda Bank Links Noted","type":"news_article","url":"https://cambojanews.com/h-pay-emerges-from-sanctioned-huione-pay-panda-bank-links-noted/"},{"credibility":2,"name":"AMBCrypto: US Treasury Targets Huione Workaround as FinCEN Moves Against H-Pay","type":"news_article","url":"https://ambcrypto.com/us-treasury-targets-huione-workaround-as-fincen-moves-against-h-pay-in-crypto-scam-crackdown/"},{"credibility":2,"name":"Cambodianess: Locked Out of Their Savings, Huione Pay Customers Demand Answers as Protest Turns Violent","type":"news_article","url":"https://cambodianess.com/article/locked-out-of-their-savings-huione-pay-customers-demand-answers-as-protest-turns-violent"}]},{"content":"The Huione Group is a Cambodia-based corporate conglomerate whose subsidiaries include Huione Pay (payment services), Huione Crypto (digital asset exchange), and Huione Guarantee (also known as Haowang Guarantee), a Telegram-based illicit marketplace. Blockchain analytics firm Elliptic, whose intelligence was used by the FBI in the June 2026 enforcement action, reported that Huione Guarantee received more than $31 billion in cryptoasset transactions over its operational lifetime, making it the largest illicit online marketplace ever recorded — more than 25 times larger than Silk Road and AlphaBay combined. The payments arm, Huione Pay, processed at least $103 billion in cryptoasset payments in total, bringing the combined figure attributed to the broader network to approximately $134 billion. FinCEN's formal findings, covering the period August 2021 to January 2025, documented at least $4 billion in verifiable illicit proceeds received by Huione Group. Huione Guarantee offered vendors a marketplace to sell: stolen personal and financial data; money laundering services; web development tools for fraudulent investment platforms and phishing sites; software for face swapping, voice cloning, and deepfake-powered impersonation; and procurement of individuals for human trafficking. Telegram banned the marketplace's channels in May 2025, though successor markets emerged thereafter.","heading":"Huione Group: Scale and Nature of Illicit Operations","severity":"critical","sources":[{"credibility":2,"name":"Elliptic: Elliptic Intelligence Used by the FBI in Action Against Huione, the $134 Billion Criminal Marketplace","type":"research","url":"https://www.elliptic.co/media-center/elliptic-intelligence-used-by-the-fbi-in-action-against-huione-group"},{"credibility":2,"name":"Business Wire: Elliptic Intelligence Used by the FBI in Action Against Huione","type":"news_article","url":"https://www.businesswire.com/news/home/20260623117806/en/Elliptic-Intelligence-Used-by-the-FBI-in-Action-Against-Huione-the-$134-Billion-Criminal-Marketplace-and-Money-Laundering-Operation"},{"credibility":1,"name":"FinCEN: Finds Cambodia-Based Huione Group to be of Primary Money Laundering Concern","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern"}]},{"content":"FinCEN's formal designation of Huione Group identified the conglomerate as a critical node for laundering proceeds of cyber heists attributed to the Democratic People's Republic of Korea (DPRK). Of the at least $4 billion in illicit proceeds documented by FinCEN between August 2021 and January 2025, at least $37 million derived from DPRK-linked cyber heists. Additional investigative reporting identified a specific instance in which Huione Group received approximately $35 million in stolen cryptocurrency later attributed by the FBI to North Korea's Lazarus Group, stolen in the May 2024 hack targeting DMM, a Japanese virtual asset service provider. Between June 2023 and February 2024, a cryptocurrency wallet associated with the Lazarus Group sent cryptocurrency valued at over $150,000 to Huione Group. As H-Pay Service PLC is alleged by FinCEN to have assumed Huione Pay's operational role, the U.S. government treats it as part of the same network that facilitated these transactions.","heading":"DPRK Cyber Heist Connections","severity":"critical","sources":[{"credibility":1,"name":"FinCEN: Finds Cambodia-Based Huione Group to be of Primary Money Laundering Concern","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern"},{"credibility":2,"name":"DL News: US Cuts Off Huione Over $4bn Crypto Laundering, North Korea Ties, and 'Unfreezable' Stablecoin","type":"news_article","url":"https://www.dlnews.com/articles/regulation/us-cuts-off-huione-4bn-crypto-launder-north-korea-stablecoin/"},{"credibility":2,"name":"CryptoNews.com: Cambodian Payments Firm Helped Lazarus Group Launder $150,000 in Stolen Crypto","type":"news_article","url":"https://cryptonews.com/news/cambodian-payments-firm-helped-lazarus-group-launder-150000-in-stolen-crypto/"}]},{"content":"A core alleged function of the Huione network — inherited by H-Pay's predecessor, Huione Pay — was providing financial infrastructure for 'pig butchering' (sha zhu pan) investment fraud schemes operated by transnational criminal organizations (TCOs) in Southeast Asia. These schemes involve perpetrators contacting victims via text messages, social media, or dating applications, building trust through romantic or friendship pretenses over weeks or months, and then directing victims to fraudulent digital asset investment platforms controlled by the scammers. The FBI's Internet Crime Complaint Center reported $7.2 billion in cryptocurrency investment fraud losses by Americans in 2025 alone. Treasury Secretary Scott Bessent stated in connection with the June 2026 enforcement actions: 'Scam centers in Southeast Asia steal billions of dollars from American victims each year.' FinCEN documented that Huione Group's payment and exchange arms transferred and consolidated funds from pig-butchering victims, with at least $36 million in confirmed proceeds from virtual currency investment scams laundered through the network between August 2021 and January 2025.","heading":"Pig-Butchering Scam Infrastructure","severity":"critical","sources":[{"credibility":1,"name":"Treasury: Further Dismantles Overseas Scam Operations Targeting Americans","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0538"},{"credibility":1,"name":"FinCEN: Finds Cambodia-Based Huione Group to be of Primary Money Laundering Concern","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern"},{"credibility":2,"name":"NewsBTC: DOJ Seizes Huione Cloud Backbone in Crypto Scam Money Laundering Crackdown","type":"news_article","url":"https://www.newsbtc.com/news/doj-seizes-huione-cloud-backbone-in-crypto-scam-money-laundering-crackdown/"}]},{"content":"Reporting by CamboJA News, Cambodianess, and the Phnom Penh Post has documented that Hun To — a cousin of Cambodian Prime Minister Hun Manet — held a 30% stake in Huione Pay and was listed as one of its directors. Hun To has publicly acknowledged the shareholding while denying involvement in day-to-day operations and denying control power. He Yanming, listed as the owner of Huione Crypto, also served as a Panda Bank director. Hun To and Li Xiong (another former Huione business director) resigned from Panda Bank's board in October 2024, shortly before H-Pay Service PLC was incorporated. The proximity of H-Pay's headquarters to a Panda Bank branch and the overlapping personnel between the entities have been noted by investigative reporters. These political connections are reported facts; whether they constitute facilitation of H-Pay's alleged evasion activities is an allegation that has not been adjudicated.","heading":"Political Connections: Hun Family Ties","severity":"high","sources":[{"credibility":2,"name":"CamboJA News: Hun To Admits Stake in Scam-Linked Huione Pay, Denies Involvement","type":"news_article","url":"https://cambojanews.com/hun-to-admits-stake-in-scam-linked-huione-pay-denies-involvement/"},{"credibility":2,"name":"Cambodianess: Hun To Admits 30% Share in Huione but Denies Control Power","type":"news_article","url":"https://cambodianess.com/article/hun-to-admits-30-share-in-huione-but-denies-control-power"},{"credibility":2,"name":"Phnom Penh Post: Hun To Denies Huione Pay Control","type":"news_article","url":"https://phnompenhpost.com/national/hun-to-denies-huione-pay-control-lost-shareholder-rights-no-role-in-operations-disputed-funds/"}]},{"content":"The National Bank of Cambodia revoked Huione Pay's payment services license in March 2025, following earlier suspension in September 2024. Radio Free Asia reported this as the same period in which the Huione network lost its banking license. H-Pay Service PLC's own Cambodian license was subsequently revoked in March 2026. These sequential license revocations left large numbers of ordinary customers unable to access their funds. Cambodianess reported that more than 1,300 customers of Huione Pay submitted identity documents and claims to the National Bank of Cambodia in December 2025 seeking recovery of their funds. Subsequent protests were reported to have turned violent. CamboJA News reported that H-Pay users were offered talks after a second gathering of affected customers. The customer harm documented in Cambodian press is distinct from, but contemporaneous with, the U.S. law enforcement actions.","heading":"Cambodian License Revocations and Customer Harm","severity":"high","sources":[{"credibility":2,"name":"Radio Free Asia: World's 'Largest Online Black Market' Loses Banking License","type":"news_article","url":"https://www.rfa.org/english/cambodia/2025/03/06/huione-cambodia-cyberscam-cryptocurrency/"},{"credibility":2,"name":"Cambodianess: Customers of US-Sanctioned Huione Pay Told to Visit NBC for Pending Payments","type":"news_article","url":"https://cambodianess.com/article/customers-of-us-sanctioned-huione-pay-told-to-visit-nbc-for-pending-payments"},{"credibility":2,"name":"CamboJA News: Second Gathering of Huione Pay Customers See Little Hope; H-Pay Users Offered Talks","type":"news_article","url":"https://cambojanews.com/second-gathering-of-huione-pay-customers-see-little-hope-h-pay-users-offered-talks/"}]},{"content":"The Huione network, including its alleged successor H-Pay, is reported to have relied heavily on stablecoins — particularly USDT (Tether) — to move and conceal illicit proceeds. DL News reported on what it described as an 'unfreezable' stablecoin linked to Huione Group's operations, designed to resist the kind of asset freezes that conventional stablecoins allow issuers to execute. The Royal United Services Institute (RUSI) published commentary on how multi-billion dollar Telegram guarantee marketplaces exploit stablecoins for scam infrastructure. Elliptic's analysis tracked the flow of cryptoasset transactions through the Huione network, providing the blockchain forensics that supported the FBI's June 2026 action. The broader enforcement context includes Americans reporting over $20 billion in total cybercrime losses in 2025, with crypto investment fraud accounting for $7.2 billion of that figure.","heading":"Stablecoin Misuse and Broader Crypto Methodology","severity":"high","sources":[{"credibility":2,"name":"DL News: US Cuts Off Huione Over $4bn Crypto Laundering, North Korea Ties, and 'Unfreezable' Stablecoin","type":"news_article","url":"https://www.dlnews.com/articles/regulation/us-cuts-off-huione-4bn-crypto-launder-north-korea-stablecoin/"},{"credibility":2,"name":"RUSI: Multi-Billion Dollar Guarantee Marketplaces Exploit Stablecoins for Scams","type":"research","url":"https://www.rusi.org/explore-our-research/publications/commentary/multi-billion-dollar-guarantee-marketplaces-exploit-stablecoins-scams"},{"credibility":2,"name":"Elliptic: Telegram Dark Markets Expand to Fill the Gap Left by Huione Guarantee","type":"research","url":"https://www.elliptic.co/blog/telegram-dark-markets-expand-to-fill-the-gap-left-by-huione-guarantee"}]}],"sources_used":[{"credibility":1,"name":"FinCEN: Proposes to Sever H-Pay Service PLC and Other Huione Group Successor Entities from the U.S. Financial System","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-proposes-sever-h-pay-service-plc-and-other-huione-group-successor"},{"credibility":1,"name":"Federal Register: Definition of Huione Group, Primary Money Laundering Concern (2026-12794)","type":"regulatory","url":"https://www.federalregister.gov/documents/2026/06/25/2026-12794/definition-of-huione-group-a-financial-institution-operating-outside-the-united-states-of-primary"},{"credibility":1,"name":"FinCEN: Issues Final Rule Severing Huione Group from the U.S. Financial System (October 2025)","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-severing-huione-group-us-financial-system"},{"credibility":1,"name":"Treasury: Further Dismantles Overseas Scam Operations Targeting Americans","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0538"},{"credibility":1,"name":"FinCEN: Finds Cambodia-Based Huione Group to be of Primary Money Laundering Concern (May 2025 NPRM)","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern"},{"credibility":1,"name":"DOJ: Justice Department Seizes Backend Infrastructure Used by the Huione Group for Money Laundering Services","type":"regulatory","url":"https://www.justice.gov/opa/pr/justice-department-seizes-backend-infrastructure-used-huione-group-money-laundering-services"},{"credibility":1,"name":"Treasury: U.S. and U.K. Take Largest Action Ever Targeting Cybercriminal Networks in Southeast Asia","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0278"},{"credibility":2,"name":"Elliptic: Elliptic Intelligence Used by the FBI in Action Against Huione, the $134 Billion Criminal Marketplace","type":"research","url":"https://www.elliptic.co/media-center/elliptic-intelligence-used-by-the-fbi-in-action-against-huione-group"},{"credibility":2,"name":"Business Wire: Elliptic Intelligence Used by the FBI in Action Against Huione","type":"news_article","url":"https://www.businesswire.com/news/home/20260623117806/en/Elliptic-Intelligence-Used-by-the-FBI-in-Action-Against-Huione-the-$134-Billion-Criminal-Marketplace-and-Money-Laundering-Operation"},{"credibility":2,"name":"Elliptic: Telegram Dark Markets Expand to Fill the Gap Left by Huione Guarantee","type":"research","url":"https://www.elliptic.co/blog/telegram-dark-markets-expand-to-fill-the-gap-left-by-huione-guarantee"},{"credibility":2,"name":"CamboJA News: H-Pay Emerges From Sanctioned Huione Pay, Panda Bank Links Noted","type":"news_article","url":"https://cambojanews.com/h-pay-emerges-from-sanctioned-huione-pay-panda-bank-links-noted/"},{"credibility":2,"name":"CamboJA News: Hun To Admits Stake in Scam-Linked Huione Pay, Denies Involvement","type":"news_article","url":"https://cambojanews.com/hun-to-admits-stake-in-scam-linked-huione-pay-denies-involvement/"},{"credibility":2,"name":"CamboJA News: Second Gathering of Huione Pay Customers See Little Hope; H-Pay Users Offered Talks","type":"news_article","url":"https://cambojanews.com/second-gathering-of-huione-pay-customers-see-little-hope-h-pay-users-offered-talks/"},{"credibility":2,"name":"Cambodianess: Hun To Admits 30% Share in Huione but Denies Control Power","type":"news_article","url":"https://cambodianess.com/article/hun-to-admits-30-share-in-huione-but-denies-control-power"},{"credibility":2,"name":"Cambodianess: Locked Out of Their Savings, Huione Pay Customers Demand Answers as Protest Turns Violent","type":"news_article","url":"https://cambodianess.com/article/locked-out-of-their-savings-huione-pay-customers-demand-answers-as-protest-turns-violent"},{"credibility":2,"name":"Cambodianess: Customers of US-Sanctioned Huione Pay Told to Visit NBC for Pending Payments","type":"news_article","url":"https://cambodianess.com/article/customers-of-us-sanctioned-huione-pay-told-to-visit-nbc-for-pending-payments"},{"credibility":2,"name":"Phnom Penh Post: Hun To Denies Huione Pay Control","type":"news_article","url":"https://phnompenhpost.com/national/hun-to-denies-huione-pay-control-lost-shareholder-rights-no-role-in-operations-disputed-funds/"},{"credibility":2,"name":"Decrypt: DOJ Seizes Huione Infrastructure Linked to Billions in Crypto Laundering","type":"news_article","url":"https://decrypt.co/371950/doj-seizes-huione-infrastructure-linked-to-billions-in-crypto-laundering"},{"credibility":2,"name":"Yahoo Finance / Reuters: DOJ Seizes Huione Infrastructure Linked to Billions in Crypto Laundering","type":"news_article","url":"https://finance.yahoo.com/markets/crypto/articles/doj-seizes-huione-infrastructure-linked-114927633.html"},{"credibility":2,"name":"AMBCrypto: US Treasury Targets Huione Workaround as FinCEN Moves Against H-Pay","type":"news_article","url":"https://ambcrypto.com/us-treasury-targets-huione-workaround-as-fincen-moves-against-h-pay-in-crypto-scam-crackdown/"},{"credibility":2,"name":"ABA Banking Journal: FinCEN Takes Further Steps to Sever Cambodian Firm from U.S. Financial System","type":"news_article","url":"https://bankingjournal.aba.com/2026/06/fincen-takes-further-steps-to-sever-cambodian-firm-from-u-s-financial-system/"},{"credibility":2,"name":"DL News: US Cuts Off Huione Over $4bn Crypto Laundering, North Korea Ties, and 'Unfreezable' Stablecoin","type":"news_article","url":"https://www.dlnews.com/articles/regulation/us-cuts-off-huione-4bn-crypto-launder-north-korea-stablecoin/"},{"credibility":2,"name":"Radio Free Asia: World's 'Largest Online Black Market' Loses Banking License","type":"news_article","url":"https://www.rfa.org/english/cambodia/2025/03/06/huione-cambodia-cyberscam-cryptocurrency/"},{"credibility":2,"name":"RUSI: Multi-Billion Dollar Guarantee Marketplaces Exploit Stablecoins for Scams","type":"research","url":"https://www.rusi.org/explore-our-research/publications/commentary/multi-billion-dollar-guarantee-marketplaces-exploit-stablecoins-scams"},{"credibility":2,"name":"CryptoNews.com: Cambodian Payments Firm Helped Lazarus Group Launder $150,000 in Stolen Crypto","type":"news_article","url":"https://cryptonews.com/news/cambodian-payments-firm-helped-lazarus-group-launder-150000-in-stolen-crypto/"},{"credibility":2,"name":"NewsBTC: DOJ Seizes Huione Cloud Backbone in Crypto Scam Money Laundering Crackdown","type":"news_article","url":"https://www.newsbtc.com/news/doj-seizes-huione-cloud-backbone-in-crypto-scam-money-laundering-crackdown/"},{"credibility":2,"name":"The Hacker News: DoJ Seizes Huione Cloud Account Tied to Cyber Scam Money Laundering","type":"news_article","url":"https://thehackernews.com/2026/06/doj-seizes-huione-cloud-account-tied-to.html"}],"summary":"H-Pay Service PLC is a Cambodia-based payment company incorporated in October 2024 that U.S. regulators allege is a successor entity to Huione Pay, itself a subsidiary of the Huione Group — a conglomerate FinCEN designated as a primary money laundering concern in October 2025 for laundering at least $4 billion in illicit proceeds linked to North Korean state-sponsored cyber heists and Southeast Asian pig-butchering scam networks. On June 23–24, 2026, FinCEN proposed amending its Huione Group final rule to explicitly encompass H-Pay Service PLC and any future successors, while the DOJ simultaneously seized backend cloud infrastructure used by Huione Group subsidiaries to process billions in fraud proceeds. H-Pay is alleged to have assumed Huione Pay's branches, customer base, branding, and operational footprint specifically to circumvent the existing U.S. financial restrictions imposed on Huione Group.","timeline":[{"date":"2021-08-01","event":"Huione Group begins receiving illicit proceeds — the start date cited in FinCEN's formal analysis covering August 2021 to January 2025.","source":"FinCEN Final Rule (October 2025)","source_url":"https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-severing-huione-group-us-financial-system"},{"date":"2024-05-01","event":"Lazarus Group (DPRK) hacks Japanese virtual asset service provider DMM, stealing approximately $305 million; approximately $35 million later attributed to have transited Huione Group.","source":"CryptoNews.com / FinCEN","source_url":"https://cryptonews.com/news/cambodian-payments-firm-helped-lazarus-group-launder-150000-in-stolen-crypto/"},{"date":"2024-07-01","event":"Elliptic publishes first major exposure of Huione Guarantee as the world's largest illicit online Telegram marketplace.","source":"Elliptic","source_url":"https://www.elliptic.co/media-center/elliptic-intelligence-used-by-the-fbi-in-action-against-huione-group"},{"date":"2024-09-01","event":"National Bank of Cambodia suspends Huione Pay's payment services license.","source":"Radio Free Asia / Cambodianess","source_url":"https://www.rfa.org/english/cambodia/2025/03/06/huione-cambodia-cyberscam-cryptocurrency/"},{"date":"2024-10-01","event":"H-Pay Service PLC incorporated in Cambodia according to the country's business registry. Hun To and Li Xiong resign from Panda Bank's board of directors.","source":"CamboJA News","source_url":"https://cambojanews.com/h-pay-emerges-from-sanctioned-huione-pay-panda-bank-links-noted/"},{"date":"2025-01-01","event":"FinCEN's formal analysis of Huione Group illicit proceeds covers through this date — at least $4 billion total documented.","source":"FinCEN","source_url":"https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern"},{"date":"2025-03-06","event":"National Bank of Cambodia formally revokes Huione Pay's banking/payment services license.","source":"Radio Free Asia","source_url":"https://www.rfa.org/english/cambodia/2025/03/06/huione-cambodia-cyberscam-cryptocurrency/"},{"date":"2025-05-01","event":"FinCEN issues proposed rulemaking identifying Huione Group as a financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act.","source":"FinCEN","source_url":"https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern"},{"date":"2025-05-01","event":"Telegram bans Huione Guarantee's channels. Successor dark marketplaces emerge to fill the void.","source":"Elliptic","source_url":"https://www.elliptic.co/blog/telegram-dark-markets-expand-to-fill-the-gap-left-by-huione-guarantee"},{"date":"2025-10-14","event":"FinCEN issues final rule severing Huione Group from the U.S. financial system. UK Foreign, Commonwealth and Development Office and OFAC take complementary actions on the same date.","source":"FinCEN","source_url":"https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-severing-huione-group-us-financial-system"},{"date":"2025-12-01","event":"Approximately 1,300 Huione Pay customers submit identity documents and claims to the National Bank of Cambodia seeking recovery of frozen funds.","source":"Cambodianess","source_url":"https://cambodianess.com/article/customers-of-us-sanctioned-huione-pay-told-to-visit-nbc-for-pending-payments"},{"date":"2026-03-01","event":"H-Pay Service PLC's own Cambodian license is revoked.","source":"CamboJA News / AMBCrypto","source_url":"https://ambcrypto.com/us-treasury-targets-huione-workaround-as-fincen-moves-against-h-pay-in-crypto-scam-crackdown/"},{"date":"2026-06-23","event":"U.S. DOJ announces seizure of cloud computing account used by Huione Group subsidiaries. FinCEN simultaneously issues NPRM to extend Huione Group final rule to H-Pay Service PLC and any future successor entities. Treasury also announces OFAC designations targeting 9 individuals and 26 entities linked to Prince Group TCO.","source":"DOJ / FinCEN / Treasury","source_url":"https://www.justice.gov/opa/pr/justice-department-seizes-backend-infrastructure-used-huione-group-money-laundering-services"},{"date":"2026-06-25","event":"FinCEN NPRM (document 2026-12794) published in the Federal Register, formally proposing to extend the Huione Group primary money laundering concern designation to H-Pay Service PLC and successor entities.","source":"Federal Register","source_url":"https://www.federalregister.gov/documents/2026/06/25/2026-12794/definition-of-huione-group-a-financial-institution-operating-outside-the-united-states-of-primary"}]},"v":1}Verify offline (run on your own machine)python -m src.verify_decision c2308438-4c19-4d76-9f19-454dbd7179fc
How verification works. The “Row integrity” check above is computed in your browser — your machine recomputes the SHA-256 of the canonical bytes and compares against the stored hash. No avoid.net server can fake that check. The “full verify” link goes one level deeper: your browser fetches the on-chain transaction from a Solana RPC node and confirms the same hash is in the memo. If you don’t want to trust either avoid.net or the public RPC, run the CLI verifier on your own machine —
python -m src.verify_decision <event_id>.