$123 million in plain sight: How laundering disguised itself as a regular forex business

What a Queen Street forex case tells us about modern money laundering detection

For more than two years, large amounts of illicit cash moved through New Zealand’s financial system without triggering the kind of intervention many would expect. This was not driven by offshore secrecy, complex corporate structures, or hidden figures manipulating cryptocurrency. It happened through a foreign exchange business on Auckland’s Queen Street, operating openly during normal business hours.

Between January 2018 and November 2020, around $123 million linked to drug trafficking, fraud and smuggling passed through the business. On the surface, it looked like a legitimate money services provider. Policies were in place. Customers were onboarded. Transactions were recorded.

The case does not show how money laundering bypasses systems entirely. Instead, it shows how it can continue when activity looks routine, fragmented, and compliant enough to avoid immediate concern.

In 2025, the High Court approved forfeiture orders requiring the operator, Musabayoufu Fuati, to forfeit approximately $600,000. While that outcome was small relative to the volume processed, the case is useful for what it reveals about how laundering is identified after the fact, and what regulators increasingly expect reporting entities to pick up much earlier.

A laundering model built on familiarity

Fuati and his associate Daniel Hu, also known as Jun Jin, did not fit the stereotype of organised crime figures. They acted as intermediaries, providing a laundering service to others rather than committing the underlying crimes themselves.

Clients paid commissions estimated at 10 to 20 percent to have cash introduced into the banking system and, in some cases, transferred offshore. Over time, the process became more refined and repeatable. Police later described the offending as deliberate and commercial.

This was not a one-off exploitation of a weakness in the system. It was a model designed to sit comfortably inside it.

Why scale on its own misses the point

Money laundering cases are often judged by size. Was this unusually large? Was it an outlier?

Those questions matter less than whether the activity was inherently exceptional, or only obvious in hindsight.

Authorities estimate that billions of dollars in criminal proceeds are generated and laundered through New Zealand each year. Against that backdrop, $123 million is significant but not implausible. What stands out is how long the activity continued while appearing operationally normal.

There is no public indication that this foreign exchange business was under unusual scrutiny during the relevant period. Nor is there evidence that a wide group of similar businesses were being investigated at the same time. Viewed transaction by transaction, the activity did not clearly separate itself from legitimate operations.

That reflects a broader reality in AML. Laundering is rarely identified because of one bad transaction. It is identified once patterns are allowed to speak for themselves.

Red flags that only made sense together

No single transaction triggered the investigation. Concern built as behaviour was examined over time.

Indicators that later became significant included:

• Repeated cash transactions that did not align with the apparent size or customer base of the business
• Deliberate structuring of deposits to avoid reporting thresholds
• Use of multiple bank accounts and third-party depositors
• Transaction activity that lacked a clear or consistent commercial purpose
• Operational influence exercised by individuals who did not appear in ownership or governance records

Each of these can exist in legitimate contexts. Taken together, they painted a very different picture.

Beyond sentencing: what actually changed

Both Fuati and Hu pleaded guilty and received home detention sentences. The penalties reflected New Zealand’s sentencing framework, the non-violent nature of the offending, and the weight given to early guilty pleas.

Proceeds-of-crime action was more significant in practical terms. Assets initially restrained were valued at around $1.17 million, with approximately $600,000 ultimately forfeited. Some assets were released as relationship property to Fuati’s partner, who was not alleged to have been aware of the offending.

What does this signal for AML frameworks

This case signals a clear shift in how authorities expect AML frameworks to operate. The focus is moving away from box-ticking at onboarding and formal ownership checks, and toward how a business actually behaves over time, whether its activity makes economic sense, who is exercising real control, and how patterns develop across transactions. For reporting entities, the implication is practical rather than theoretical: ongoing monitoring matters more than static checks, structuring remains a meaningful risk indicator even when individual transactions are small, and foreign exchange or remittance businesses using large volumes of cash or repeated third-party depositors deserve closer scrutiny.

The core lesson

This case did not rely on secrecy or sophistication. It relied on familiarity.

Money laundering increasingly operates through businesses that look legitimate, behave predictably, and generate paperwork that appears compliant. The challenge is not access to information, but the willingness to question whether the activity actually makes sense.

When laundering hides in plain sight, detection depends on joining the dots before enforcement has to do it for us.