The Supreme People’s Procuratorate (SPP) and the Ministry of Public Security have jointly issued five typical cases on punishing money-laundering crimes in accordance with the law, according to a report by The Paper published on November 11, 2026. The report says the release is intended to carry out central Party decisions on anti-money-laundering work and to show results from coordinated procuratorial and police action since a three-year campaign against money-laundering offenses.
The five cases cover the use of financial intelligence, separate prosecution of money laundering, punishment of money laundering by a unit, underground banks, and the use of shell companies. Predicate offenses include illegally absorbing public deposits, corruption and bribery, and fundraising fraud. The report says the cases overall involve varied methods, complex circumstances and very large sums.
A lead prosecutor in the SPP Economic Crime Procuratorial Department said the selected cases focus on difficult issues in case handling, including how to distinguish money laundering from the predicate offense, how to distinguish the crime of illegal business operations from money laundering, and how to strengthen full-chain evidence review. The prosecutor said this should help case handlers apply the standard for money laundering more accurately and improve the quality and effectiveness of casework.
The report says procuratorates and public security organs have adhered to “one case, dual investigation,” examining complex laundering through the transactions, tracing funds and pursuing the full chain. In the case of Gong Mouyi, investigators traced the source, path, actual controller and final destination of funds and identified false transactions, nominee shareholding and bridge transfers used to conceal criminal proceeds. In the case of Hu Mouyu and five others, the report says investigators sought the effect of “striking one laundering group, destroying one criminal chain and restraining multiple predicate crimes.”
The report also highlights multi-party cooperation. In the case of Wang Moufang, procuratorates and police worked with the People’s Bank of China and other anti-money-laundering institutions to share and jointly assess intelligence, uncover leads and trace the full chain of laundering.
The same prosecutor said the cases are meant to explain common laundering methods and their social harm through concrete examples, raise public awareness, and guide procuratorates and police so that high-quality case handling supports high-quality economic and social development.
The notice
A notice from the SPP and the Ministry of Public Security, dated November 3, 2026, is addressed to procuratorates and public security departments of provinces, autonomous regions and municipalities directly under the central government, the military procuratorate of the People’s Liberation Army, and the procuratorate and public security bureau of the Xinjiang Production and Construction Corps.
The notice says the five cases were jointly selected to consolidate the three-year campaign, increase punishment of money laundering, improve case quality and raise public awareness. It asks recipients to study and draw on the cases in light of their own work.
Case 1: Wang Moufang — financial intelligence and administrative-criminal linkage
Keywords given in the release: money laundering; illegally absorbing public deposits; financial intelligence; linkage between administrative enforcement and criminal justice.
Wang Moufang, a woman, is described as the former wife of Xu Mouming, a suspect in a separate illegal-fundraising case. From 2013 to 2020, Xu and others, without permission from the financial regulator, used Beijing A Pension Industry Investment Management Co. and other companies to promote pension-base and other investment projects by telephone sales, organized travel and publicity meetings. Using pension services as a pretext, they signed membership-service and loan contracts, promised to return principal and pay high returns within a set period, and raised more than 100 million yuan from the public.
From 2017 to 2019, Wang provided her bank account to Xu and others as a fund-pool account and received more than 70 million yuan in raised funds. She used illegal funds transferred into the account to buy insurance wealth-management products on three occasions, totaling 6 million yuan. She received more than 1.07 million yuan in policy cash and used the remaining policies as collateral for loans. At the time of the case, unpaid principal and interest totaled more than 2.6 million yuan.
The Beijing branch of the People’s Bank of China found abnormal transactions in accounts related to A Investment and, after analysis, transferred a suspected money-laundering lead to the police under the Anti-Money Laundering Law. The Fengtai branch of the Beijing Public Security Bureau, while establishing Xu’s illegal absorption of deposits, found facts suggesting Wang had laundered money and assessed the case with prosecutors. After Xu was placed under investigation for illegally absorbing public deposits, Wang surrendered in May 2023 and truthfully confessed. Fengtai police then opened a money-laundering investigation.
In August 2023, Fengtai police transferred the case for prosecution. The Fengtai District People’s Procuratorate used a fund-inquiry mechanism with the People’s Bank to fix evidence of transfers, and police froze more than 2.6 million yuan in policy cash value. Prosecutors concluded that, while living with Xu, Wang learned some facts of the illegal fundraising through conversations among Xu and relatives, and that a participant who knew her had contacted her seeking repayment, so she ought to have known the account funds were criminal proceeds. In September 2023, the procuratorate charged her with money laundering. She pleaded guilty and accepted punishment and returned 1 million yuan.
In December 2023, the Fengtai District People’s Court sentenced her to one year and six months in prison and a fine of 300,000 yuan. She did not appeal, and the judgment took effect.
The release’s stated significance is twofold. First, suspicious-transaction and other financial intelligence from obligated institutions is an important source of leads, and case-handling organs should keep improving timely sharing, transfer and joint assessment with the People’s Bank of China. Second, in illegal-fundraising cases, authorities should trace all proceeds and gains, pursue recovery while investigating laundering, and use financial-data platforms and analysis to support both prosecution and asset recovery.
Case 2: Gong Mouyi — penetrating review and a separate money-laundering prosecution
Keywords: money laundering; corruption and bribery; separate prosecution; penetrating review.
Gong Mouyi, deputy director of Company A, was a university classmate of Zhang Mou, a deputy president of a state-owned bank whose duty-related crimes were handled in a separate case. In 2014, to build a relationship with Zhang’s bank, Liu Mou, the actual controller of Company A, gave Zhang 8 percent of the company shares he held. Zhang agreed and arranged for Gong to hold the unpaid “dry shares,” given as a bribe, by taking a stake in related Company B. In April 2018, after Zhang left his post, he arranged for Gong to transfer and cash out the shares for 11.84 million yuan.
In 2014, Zhang and Liu jointly misappropriated off-balance-sheet business funds of Zhang’s bank to a company actually controlled by Liu, and the funds were then moved into accounts controlled by Gong. From 2014 to 2016, at Zhang’s direction, Gong transferred those funds in batches to securities and bank accounts opened by Zhang’s relatives and friends. Liu Mouyu, handled in a separate case, traded stocks with the money. Cumulative investment was 165 million yuan, with a profit of more than 32.56 million yuan.
After the supervisory authority opened a case on Zhang’s duty crimes, the procuratorate intervened early. A suspected laundering lead involving Gong was transferred to the police. In September 2022, the Pingfang branch of the Harbin Public Security Bureau opened a money-laundering investigation.
In June 2023, Pingfang police transferred the case for prosecution. Gong did not admit guilt. The Pingfang District People’s Procuratorate found that he was close to Zhang, knew Zhang’s occupation and lawful income, and that the transfers and use of funds were plainly abnormal, and concluded he ought to have known the funds were proceeds of bribery and misappropriation of public funds and that he concealed their source and nature. Although Zhang had not yet been prosecuted, prosecutors found the predicate crime did exist. In July 2023, the procuratorate prosecuted Gong for money laundering first.
In December 2023, the Pingfang District People’s Court sentenced him to eight years and six months in prison and a fine of 200,000 yuan. He appealed. In June 2025, the Harbin Intermediate People’s Court rejected the appeal and upheld the judgment.
While investigating the stock accounts and transfers, Pingfang police found that Liu Mouyu and Tong Mou, acting on instructions from Zhang and Gong, had used stock and bank accounts to move and hide illicit money. Both were investigated, prosecuted and convicted of money laundering.
The release says that, where the predicate crime has not yet been adjudicated, downstream money laundering may still be prosecuted if evidence shows the predicate crime “indeed exists,” the standard in Article 7 of the Supreme People’s Court and Supreme People’s Procuratorate interpretation on the application of law in money-laundering cases. It also says nested financial tools require a full account of source, path, controller and destination, and that participants who commit money laundering should be pursued along the whole chain.
Case 3: Shanghai A Financial and Song Moujiao — tracing funds and unit crime
Keywords: money laundering; fundraising fraud; money laundering by a unit; commingling of funds.
The defendant unit is Shanghai A Financial Information Services Co. Song Moujiao, a man, was the actual controller of A Financial and related companies.
In June 2014, Song founded A Financial and used it as a holding platform to set up Shanghai B Financial Information Services Co. and other affiliates for loan-facilitation, e-commerce and other business. From July 2015 until the case, A Financial, without regulatory permission, developed a wealth-management platform actually operated by B Financial, publicly promoted products to the public and promised high returns. When profits were insufficient to pay principal, interest and operating costs, it continued raising funds, collecting more than 1.9 billion yuan, used mainly to repay investors, cover daily operations and lend among related parties. More than 41 million yuan could not be repaid.
In December 2016, Song separately founded C Factoring, which the release says did not take part in A Financial’s illegal fundraising. With pilot approval and filing by the local financial regulator, it conducted receivables financing and other commercial factoring. From March to June 2021, Song directed A Financial’s finance staff to transfer more than 6.3 million yuan of illegally raised funds, in several payments, into C Factoring’s account, where they were mixed with lawful operating funds. C Factoring used them to take on receivables and perform guarantee obligations, then used recovered funds and returns for further factoring. A judicial audit found the funds did not flow back to A Financial.
In July 2021, the Pudong branch of the Shanghai Public Security Bureau opened an investigation of B Financial for illegally absorbing public deposits. With prosecutors, police later determined that Song was suspected of fundraising fraud and, by following the money to C Factoring, arrested 23 people, including principal offender Song, on suspicion of fundraising fraud, illegally absorbing public deposits and money laundering.
In August 2022, Pudong police transferred Song for prosecution on fundraising fraud and money laundering. The Pudong New Area People’s Procuratorate found that both the fraud and the laundering were carried out in A Financial’s name, reflected the unit’s will and benefited the unit, so the company should bear unit criminal liability. In October 2022, it prosecuted A Financial and Song for both offenses. Prosecutors pressed for restitution; more than 31 million yuan was recovered in the case.
In June 2023, the Pudong New Area People’s Court fined A Financial 2 million yuan for fundraising fraud and money laundering. It sentenced Song to eight years and a fine of 700,000 yuan for fundraising fraud, and two years and a fine of 200,000 yuan for money laundering. Combined, the sentence was nine years and a fine of 900,000 yuan. He did not appeal, and the judgment took effect.
The release says money laundering can be committed by a natural person or a unit, and that conduct based on a unit’s will, in the unit’s name and for the unit’s benefit should be treated as unit crime, while lawful business must be distinguished from illegal activity. It also says that moving illegal fundraising proceeds out of the fundraising model, into other accounts or into lawful income in order to conceal their source and nature, can constitute both fundraising fraud and money laundering. Using those funds to repay principal and interest or pay wages in order to keep the illegal fundraising model running is generally part of the predicate offense and is not ordinarily treated as money laundering.
Case 4: Hu Mouyu and five others — full-chain enforcement and illegal business operations
Keywords: money laundering; fundraising fraud; full-chain enforcement; illegal business operations.
Hu Mouyu, a man, was the actual person in charge of Fujian A Music Production Co. Huang Mou, a man, was a shareholder and finance officer. The release omits basic details of the other four defendants.
In March 2021, Hu and others founded A Music. Staff sent false charts, transfer records and chat records that exaggerated the prospects of investing in music copyrights, promised high returns and raised public funds in the name of copyright investment. From March 2021 to August 2022, the company raised more than 20.6 million yuan. Most was spent personally or paid as high commissions to the business team, and more than 19.8 million yuan could not be repaid.
To conceal the proceeds, Hu and Huang, without real transactions, fabricated consulting and service agreements and a false business chain. Fraud proceeds passed briefly through the corporate account of a company of Lin Moumou, handled separately, moved through multiple account levels and returned to accounts of Hu, Huang and others, totaling more than 7.72 million yuan.
On November 23, 2021, the Taijiang branch of the Fuzhou Public Security Bureau opened a fundraising-fraud investigation of A Music. After further consultation with prosecutors, police determined the company’s main business after incorporation was absorbing public funds and that the offense should not be treated as a unit crime. Investigation then focused on Hu, Huang and others.
Taijiang police transferred Hu, Huang and four others for prosecution on December 30, 2022, and June 1, 2023. The Taijiang District People’s Procuratorate, working with police, found that Hu and Huang had self-laundered and added money-laundering charges. From March to June 2023, it prosecuted Hu and Huang for fundraising fraud and money laundering, and the other four for fundraising fraud.
From August to November 2023, the Taijiang District People’s Court sentenced Hu to 12 years and a fine of 700,000 yuan for fundraising fraud, and five years and three months and a fine of 1.7 million yuan for money laundering, combined as 14 years and a fine of 2.4 million yuan. Huang received 10 years and a fine of 500,000 yuan for fundraising fraud, and three years and six months and a fine of 1.7 million yuan for money laundering, combined as 12 years and a fine of 2.2 million yuan. The other four received sentences for fundraising fraud ranging from seven years and six months to five years and one month, plus fines. Hu, Huang and two others appealed. In December 2023, the Fuzhou Intermediate People’s Court rejected the appeals and upheld the judgments.
Using a suspicious-transaction inquiry mechanism between the Fujian branch of the People’s Bank of China and the judicial authorities, investigators followed the lead from Lin Moumou to Zeng Mou and Chen Moumou, who were suspected of providing accounts to move funds. Counterparties were spread across the country and the sums were very large; the release describes them as a group specializing in illegal payment and settlement. The three were arrested and investigated for illegal business operations. Investigators also found that Fujian B Film and Television Culture Development Co., already under investigation, had used an account of a company actually controlled by Zeng to self-launder illegal fundraising proceeds. Police added a money-laundering charge against B Film’s principal offender, who had not been brought in, and added self-laundering facts against two people already in custody.
The release says case handlers should track the full process in both directions: from the predicate crime to the laundering and its payment channels, and from those channels to other predicate crimes. It distinguishes illegal business operations—providing unlawful fund transfers, cash-out, payment settlement or currency exchange in violation of financial rules—from money laundering, which requires knowledge that the funds are proceeds or gains of one of the seven categories of predicate crime in Article 191 of the Criminal Law, together with acts of concealment. It says the nature of the conduct should be decided by examining source, subjective knowledge, business model, clients, path and destination.
Case 5: Li Moulei — cross-regional cooperation and shell companies
Keywords: money laundering; fundraising fraud; shell companies; cross-regional cooperation.
Li Moulei is described as the maternal uncle of Wang Moushuai, the perpetrator of an upstream fundraising-fraud case handled separately. Around 2022, Wang formed a fundraising-fraud group centered on A Group Holdings Co. With the purpose of illegal possession and without real transactions, the group used the claim that buying cosmetics would bring high rebates to absorb public funds, and many participants suffered losses.
From December 2022 to August 2023, Li, knowing the funds Wang had absorbed were proceeds of fundraising fraud, registered 14 shell companies with no real business. He agreed with Wang that fraud proceeds would be transferred into those company accounts and then moved through repeated transfers. Li charged a “handling fee” of eight-thousandths of the amount moved. Before the case, he helped transfer more than 2.9 billion yuan, withdrew 5 million yuan in cash and illegally gained more than 24 million yuan.
In August 2023, the Zhanhe branch of the Pingdingshan Public Security Bureau in Henan received a financial institution’s report of abnormal transactions in a local company account. It initially assessed the conduct as illegal payment settlement and opened an illegal-business investigation of Li. Further review found he was mainly moving illegal funds for Wang, who was already under investigation by the Shenzhen Public Security Bureau in Guangdong for fundraising fraud. Police in Henan and Guangdong worked together to clarify facts in both places and froze more than 28 million yuan of Li’s involved funds.
In December 2023, Zhanhe police transferred the case as suspected illegal business operations. The Zhanhe District People’s Procuratorate reviewed the evidence, including the family relationship, long-running fund flows and the registration of many shell companies, and concluded the evidence was sufficient to show Li ought to have known the funds were proceeds of fundraising fraud and that the offense was money laundering. In May 2024, it prosecuted him for money laundering.
In September 2024, the Zhanhe District People’s Court sentenced him to seven years and six months in prison and a fine of 3.8 million yuan. He did not appeal, and the judgment took effect.
The release says rapid, frequent movement of raised funds among companies calls for substantive review of registration background, operations and expenditure, and for cross-checking data to tell genuine business from a laundering channel. Where the predicate crime and the laundering are investigated in different regions, it says authorities should share information, transfer leads and verify evidence so both levels of crime can be pursued and assets recovered together.
Original report: The Paper
