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

Asset 4received two deposits totalling £130,000.00 from Mr Xing’s long-held HBOS account ending 664. This account (ending 664) had accrued £698,742.26 from suspected unlawful activity, in addition to those used for Assets 1 to 3. Excluding overseas transfers, Mr Xing’s HBOS account ending 664 received £549,669.15 between September 2018 and March 2024, which is 7.65 times greater than his declared gross income of £71,803.44 for the same period. The number, stated sources, and amounts of money transferred into Mr Xing’s HBOS account appear specifically arranged to avoid detection in relation to Chinese monetary restrictions. Three of the overseas transfers into this account appear to be in Mr Xing’s name, despite him being a UK resident since 2002. Two additional overseas transfers in relation to Asset 4 came from Mr Xing’s mother and a ‘Qu Xuan’. The transfer of monies from family and friends is, I was told, noted to be another tactic used in Chinese Underground Banking to avoid detection in relation to Chinese monetary restrictions.

Overall, Mr Woollard’s financial analysis identifies 103 ‘Transfers In’ totalling £1,867,046.22 into the Respondents’ personal UK bank accounts between 6 April 2010 and 30 April 2024. Many of these were from accounts in China, which on their face may contravene Chinese money movement restrictions. The money movements are suspected to originate from Daigou and money laundering activity, facilitated by the laundering of criminal cash through the Respondents’ personal bank accounts. This suspicion arises from the volume and value of transfers from China, the frequency and spread of cash deposits (2010-2018), and third-party monetary transfers (2018-2024). The analysis carried out supports the suspicion that the Respondents have committed money laundering offences and further offences under the MLR 2017 by acting as unregistered MSBs using a suspected IVTS to move suspected criminal funds via Chinese underground banking.