Cross-Border Investment Fraud

Cross-border investment fraud exploits the gaps between national regulators. By operating across multiple jurisdictions, fraudulent networks ensure that no single authority has complete oversight. The Corinth Group investigation spans seven jurisdictions — Switzerland, the United Kingdom, Cyprus, Luxembourg, India, South Africa, and Hong Kong.

The Multi-Jurisdiction Strategy

The cross-border corporate structure distributes its operations across countries for several reasons: different jurisdictions have different regulatory requirements; regulatory action in one country does not automatically affect entities in another; cross-border information sharing between regulators is slow and limited; and victims in different countries often cannot easily coordinate with each other or identify the full scope of the operation.

Corinth Group: Seven Jurisdictions

The Corinth Group network illustrates this strategy. In Switzerland, six AGs are registered in Canton Graubunden — including Corinth Investment Holdings AG (CHE-102.223.770) [Zefix]. In the United Kingdom, Three Tuns Investment Holdings Ltd (14242045) and 20+ other companies are registered [Companies House]. In Cyprus, Corinth Fund Management Ltd held (and lost) an AIFM licence. The RAIF fund vehicle was structured under Luxembourg law. A claimed $100M investment targeted an Indian listed company (Morepen Laboratories). Complainants have filed reports from South Africa and the United States. The earliest entity referenced is APAHML, registered in Hong Kong.

Regulatory Gaps

When CySEC revoked Corinth Fund Management Ltd's AIFM licence (AIFM48/56/2013) in October 2022, the Swiss and UK entities were unaffected — they were not regulated by CySEC [CySEC AIFM register]. No Swiss entity holds a FINMA licence. No UK entity holds FCA authorisation. Each regulator sees only its own piece of the network, making it difficult to assess the full picture.

Complainants Cannot Easily Coordinate

Victims in different countries face different legal systems, different languages, and different complaint procedures. A South African investor filing with SAPS, an Austrian investor filing with Austrian police, and a UK investor filing with Action Fraud may all be targeting the same network — but without coordination, each complaint appears isolated. The Corinth Group investigation has identified complainants across at least five countries.

What Needs to Happen

Cross-border fraud investigations require: coordinated filing of complaints with multiple national regulators simultaneously; sharing of evidence between victim groups across countries; engagement of regulators with cross-border mandates (e.g., Eurojust, Interpol); and public documentation that allows victims in different countries to recognise the common pattern.

Key Facts

• Network spans 7 jurisdictions: Switzerland, UK, Cyprus, Luxembourg, India, South Africa, Hong Kong
• CySEC licence revocation did not affect Swiss or UK entities
• No single regulator has oversight of the full network
• Complainants identified across at least 5 countries
• No entity in the network currently holds any financial regulatory licence

Complaint Reports

People Involved

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