AC-2025-LON-002199 - [2025] EWHC 2057 (Admin)

Asset 3 was purchased for £250,000 on 1 March 2024, again without a mortgage. Four payments totalling £260,103.95 were made to K and K Solicitors Ltd between November 2023 and February 2024. The source of a £25,000 payment from Ms Zhang’s account and further transfers of £20,000 and £7,500 into her account were effectively enabled by transfers from an overseas account held by a ‘Yan Zhang’ in Beijing, China. A payment of £234,208.96 from Ms Zhang’s Lloyds account was derived from cash deposits, transfers from another of her accounts, and five transfers of monies from China, likely from accounts held by Ms Zhang, her mother, and her father. These payments are, similarly, not consistent with declared earnings and are suspected to be the proceeds of the Respondent’s activities as an unregistered MSB, related Daigou activity, and money laundering.