A new report by the Asia/Pacific Group on Money Laundering has found the growth of cyber scam hubs across Southeast Asia to be largely anchored around Special Economic Zones, with locations like Dara Sakor in Cambodia, the infamous Golden Triangle and even Clark in the Philippines providing the perfect storm of lax regulation and limited enforcement.
The report, titled “Cyber Scam Hubs and Human Trafficking Report 2026,” also draws a direct link to the COVID-19 pandemic, which saw many casinos and hotels operated by criminal syndicates within these zones no longer able to generate sufficient proceeds due to lockdowns. As such, these casinos and hotels were repurposed into cyber scam hubs populated by human trafficking victims to conduct scams.
According to the findings of the report, cyber scam hubs can operate at scale in regulatory grey zones, where state authority and oversight is weak. These areas include Special Economic Zones, free-trade areas and border regions, since they do not have clear jurisdictional authorities, limited enforcement and inconsistent regulatory standards. This allows large secure compounds to be established, which are able to be relocated or rebranded when regulatory pressure increases.
It notes that cyber scam hubs are mainly located along border areas between Thailand, Myanmar, Lao PDR and Cambodia, along the northern border of Myanmar with China and the Philippines.
There are also cyber scam hubs located in Special Economic Zones like Dara Sakor and Henge Thmorda in Cambodia, the Golden Triangle special economic zone in Lao PDR, as well as the Clark Free Port Zone, Bamban in Tarlac and Cebu in the Philippines.
“These special economic zones are also often subject to low regulatory oversight, limited law enforcement presence and also provide the necessary internet access, availability of space to accommodate the operations and other facilities to support the number of people involved in these hubs,” the report states.
It notes that the proliferation of hubs in the Philippines declined significantly following the POGO ban that came into effect from 1 January 2025.
The report also highlights the complex and opaque corporate structures used by cyber scam hubs to conceal beneficial ownership and obscure the scale of operations. Assets are able to be moved across jurisdictions with minimal transparency through the use of cross-border registration chains, nominee directors and multi-layered shell companies.
Vertically integrated criminal ecosystems are difficult to regulate through a single jurisdiction AML framework, since illicit and online marketplaces, white-label online gambling and payment platforms integrate fraud-enablement tools with currency-exchange and settlement functions.
“These complex corporate structures are often established as the cyber scam hubs are being developed and operate in a similar way to large scale businesses,” the report finds.
A number of people surveyed in compiling the report noted the use of complex corporate structures, including shell or front companies, as a primary means of laundering proceeds from cyber scam hubs, while many cited the use of gatekeepers such as company service providers and lawyers.
The purpose of the “Cyber Scam Hubs and Human Trafficking Report 2026” is to raise awareness among governments, financial intelligence units, law enforcement agencies and policymakers about the convergence of cyber-enabled fraud, human trafficking and organized crime, and to encourage a coordinated regional response.
Dr Chris Black, Executive Secretary of the Asia/Pacific Group on Money Laundering, said, “The report shines a light on one of the most alarming developments in transnational organized crime across the Asia/Pacific region – the combination of cyber-enabled fraud and human trafficking. By understanding how these cyber scam hubs operate, it disrupts and disempowers the criminal networks behind them.”
Japan’s APG Co-Chair, Mitsutoshi Kajikawa, added that there are a number of existing mechanisms and networks to support coordinated action against cyber scams but that effective mitigation of these crimes requires continued monitoring, enhanced regional cooperation, targeted intelligence sharing and strong AML/CFT frameworks.
“The FATF (Financial Action Task Force) Standards provide the framework for strong AML systems and their risk-based implementation is critical,” Kajikawa said.
“There are also a number of regional and international cooperation networks, including for asset recovery, which can be used to support regional actions.
“These measures are critical to the detection, disruption and prosecution of cyber scam hub operators and the protection of victims worldwide.”
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