INCA DIGITAL
NOTHING ESCAPES INCA
◉ DEBRIEF
Cambodia handed out 4,000+ passports, mostly to Chinese nationals. The new citizens now sit on 7,284 corporate boards, six of them beside the Prime Minister's cousin. Then the government stopped publishing the records.
Morning,
I'm starting this newsletter to spread the important stories, the suspicious, strange, and scary risks Incas are seeing in the depth of dark money and digital crime.
Nation-states stealing billions. Scam compounds pulling double duty as military installations, sucking money and life out of innocent people. Third-world kingpins abusing first-world immigration pipelines and new financial instruments like crypto.
At Inca, I make it 24/7 front and center, because Inca has one job: to stop the bad guys. Alongside Federal agencies. Financial institutions. Free and fair press. For everyone fighting for a better future.
In Rio, we sharpened the mission: money went digital, and those threats followed.
In 2026, Inca goes hunting.
No mercy,
Adam Zarazinski
CEO, Inca Digital
BACKSTORY
Citizenship <> Corporate Records? Sus.
4,000+
PASSPORTS ISSUED
2000 TO 2023
36.2%
TOP PROVINCE: FUJIAN
7,284
CAMBODIAN FIRMS WITH A NATURALIZED DIRECTOR
01
Scale of Naturalization. Between 2000 and 2023, Cambodia naturalized over 4,000 foreign nationals "by royal decree." 56% came from the People's Republic of China. In 2024, the government stopped publishing the records.
02
Corporate Embedding. 5.6% of Cambodia's entire corporate registry, 7,284 entities, has at least one director who exploited the investment-for-citizenship process. Note : naturalized Cambodian citizens who become directors hold board seats at nearly, triple the rate of native-born Cambodian directors (3.6 vs 1.4). One man, Chen Zhi, holds 45 board seats.
03
Political Protection. In January, Cambodian police raided Huione Pay and arrested Li Xiong, the man who runs it. He was out within hours. No charges. No explanation.
Ministry of Interior insiders later told independent Cambodian researchers what happened: Li Xiong sits on the Huione Pay board next to Hun To, cousin of the Prime Minister.
BREAKDOWN
Chain Naturalization
◦ THE PATHWAY
Cambodia has two paths to a passport. Seven years of residency plus Khmer language, which applicants describe as expensive and corruption-laden. Or the three-month investment route: a donation to the party-state. The price was $300,000 until January, when Chen Zhi, the Prime Minister's personal advisor, was extradited to the PRC. The floor jumped to $1M or $3M overnight.
◦ THE BLACKOUT
Cross-referencing the dataset against archived versions of Cambodia's corporate registry, Incas surfaced 2,336 naturalized individuals sitting on corporate boards. Average seat count: 3.6 versus 1.4 for native-born directors. A total of 180 sit on 10 or more. Shared directorships move assets, reconstitute shells, and absorb sanctions.
◦ THE PATTERN
Hun To, cousin of Cambodia's Prime Minister and nephew of the former PM, has served on the boards of six corporate entities: Huione Pay, Huione Life, HH Bank, Proteva Insurance, and two Heng He entities. Every one of them shares a boardroom with naturalized citizens tied to Cambodia's scam industry. OFAC has sanctioned their associates. Singapore has convicted one.
Despite international scrutiny of this network, Cambodia has held no individual accountable. In one near outlier, Huione executive Li Xiong was arrested then released without explanation (likely, due to his proximity to Hun To.
On April 23, Treasury sanctioned Kok An and 28 others — many of them mapped inside our dataset. Cambodia… stopped publishing the records that built the map. We rebuilt it.
◉ HUNTING HUN TO
Central to six corporate boards.
BACKHANDED
Crushing Cambodia's Corruption.
◦ CROSS-REFERENCE
Cambodia citizenship dataset, run against corporate registry archives.
◦ CHEF’S KISS
Intelligence ops: corporate network mapping, per‑individual risk scoring, PRC‑linkage and leverage analysis, and more.
◦ DELIVER
Delivered to Treasury, the broader intelligence community, and financial institutions that want to end these activities.
READ THE RECEIPTS
INCA IRL
STORIES
The Information: JPMorgan cuts off fintech Checkbook. Adam on the visibility gap as payments rails converge.
WSJ: Maduro's crypto-backed oil deals put Tether at the center of Venezuela's money drama. Adam on the governance failures.
FT, AP, Guardian, Diplomat: Jacob Sims on Cambodia's scam empire. Same story we're breaking above.
SPEAKING
Consensus 2026. Spoke on defending infrastructure as fast as the worst offenders.
Consensus Miami. May 5.
STAFF
Brought everyone down to Rio.
Speaking of everyone, let’s welcome :
Vera M. and Ivan N., Market Data. Exchange forensics, spoofing.
Vitor H., RAD Analyst. Live market signals.
Lynnann W., Data Analytics & Infrastructure.
1 All figures are Inca Digital reporting most recent estimates based on currently available public and proprietary sources; actual values may differ due to updates in underlying data and disclosures.