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SEPTEMBER 2026 … • … ISSUE 04 … • … SCAM STATE ARCHITECTURE
◉ BRIEFING
10 SEC
The U.S. moved to seize roughly $15 billion in bitcoin tied to Cambodia-based Prince Group, the largest forfeiture in DOJ history. Its Chairman, Chen Zhi, was indicted and extradited to China. The Cambodian political structures that let him rise are still standing.
Good morning,
We previously introduced Cambodia’s scam economy in our first newsletter: The Scambodian Dream.
Since then, most of the compounds have emptied out. Roughly 300,000 scam-affiliated workers "voluntarily left" Cambodia during the 2026 crackdown. But the men who ran the state around them haven't. Hun To, cousin of the Prime Minister, publicly holds 30% of Huione Pay, untouched by any accountability.
This week, we released Scam State Architecture, a new report authored by Jake Sims and co-published with the National Democratic Institute (NDI). It explains how foreign criminal capital became embedded in Cambodia and why disruption has not reached the domestic political layers that upheld it.
No Mercy,
Adam Zarazinski
CEO, Inca Digital
BACKSTORY
CAMBODIA : THE KINGDOM THAT PROTECTS ITS OWN
01 / 04
01 — THE U.S. TOLL.
Southeast Asia-based scam networks steal more than $10 billion a year from Americans alone, per U.S. Treasury.
02 — REGIONAL BLEED.
Scam losses across the Asia-Pacific hit an estimated $114 billion in 2025, per the UNODC.
03 — CAMBODIA'S CUT.
The government's own labor-exit figures imply peak Cambodian scam revenue north of $37 billion, nearly triple prior estimates of $12.5B to $19B.
04 — THE EXODUS.
Roughly 300,000 scam-affiliated people "voluntarily left" the country during Cambodia's 2026 crackdown, the government says.
THE ARCHITECTURE OF INSULATION · THREE LAYERS, ONE SYSTEM
▌ EXTERNAL CRIMINAL CAPITAL FOREIGN · EXPENDABLE · TRACEABLE
▌ TERRITORIAL PROTECTION DOMESTIC · POLITICAL · MURKY
▌ ELITE MEDIATION FAMILY TIES ✕ SIGNAL LOST
Pressure has disrupted the first layer. It has yet to touch the third.
BREAKDOWN
HUN TO, HUIONE PAY, AND THE FAMILY THAT HOLDS THE LINE
02 / 04
Hun To, nephew of Senate President Hun Sen, cousin of Prime Minister Hun Manet, publicly holds a 30% stake in Huione Pay. He also sits on the boards of 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.
Chen Zhi, Prince Group's founder, held 45 board seats at his peak. He was indicted, extradited to China and the U.S. moved to seize roughly $15 billion in bitcoin tied to his network, the largest forfeiture action in DOJ history. Hun To has faced none of that.
BACKHANDED
NEW REPORT: SCAM STATE ARCHITECTURE
03 / 04
◦ CROSS-REFERENCING DATA
Corporate records, sanctions lists, and court filings, cross-referenced against survivor testimony to trace how the money and the people connect.
◦ ON-CHAIN, ON-THE-GROUND
Geospatial analysis and firsthand interviews, mapped against the corporate registry to show not just who's involved, but where.
◦ ACCOUNTABILITY, DELAYED BUT ARRIVING
On September 15, two House Committee chairmen demanded sanctions investigations into 24 scam-linked individuals, including Hun To. It's the clearest sign yet that lawmakers are catching up to the networks our research has been mapping for months.
◦ COMMUNICATING THE INTEL
Published with the National Democratic Institute and delivered to governments and financial institutions working to disrupt this network. Now, it's in your hands too.
INCA IRL
INSIDE INCA DIGITAL
04 / 04
SEE US
DataExpert Digital Asset Experience Conference. September 22. Arnhem, NL.
Sibos Miami. September 28. Miami, FL.
2026 Economic Statecraft Summit. October 5. Washington DC.