Background
Through an acquaintance's introduction, our client, A, took on work exchanging funds intended for use at an overseas casino. A person said to operate a casino in Southeast Asia (C) and their spouse (D) had approached A asking whether "money for use at the casino could be converted into virtual assets." Together with another acquaintance experienced in virtual asset trading (B), A spent about ten days converting Korean won into a virtual asset called Tether. Tether is designed to track the US dollar one-for-one, so it is often used for sending money abroad because it carries little exchange rate risk.
Some of the money that came into these transactions, however, turned out to have been sent by voice phishing victims who had been deceived. When one of the accounts used in the transactions was reported as suspected fraud and payments were suspended, A stopped the work immediately — but an investigation had already begun. A was placed under investigation on suspicion of having taken part in exchanging voice phishing proceeds.
What Was at Stake
The law that could apply to A punishes a person who exchanges money "knowing" it to be voice phishing proceeds. Whether A would be punished therefore turned on whether A knew, or suspected, that "this money might be voice phishing proceeds" — in legal terms, on intent.
The difficulty was that on the face of it A looked exposed. Large sums had moved, the structure involved converting funds into virtual assets and sending them abroad, and several people had worked on it together. From an investigator's standpoint it was easy to ask, "could he really not have known?" The central challenge was how to show through objective evidence A's actual state of mind — that A believed throughout that these were casino funds.
How Changchun Helped
Changchun concentrated on proving A's state of mind as a matter of fact rather than conjecture.
First, we set out from the very origins of the transactions why A could only have believed this was "casino currency exchange." We showed that exchanges of this kind are common in the Southeast Asian casino industry, and that everyone who brought A into the transactions was connected to casino operations and currency exchange. We further obtained a recording of a call establishing that even the party who proposed the transactions did not know the money was voice phishing proceeds — making it hard to conclude that A alone was aware of the circumstances.
Second, we showed in figures that the consideration A received was far too small. A's fee amounted to roughly 0.1% of the total exchanged — less than ordinary trading fees at Korea's major exchanges. The party who proposed the transactions, by contrast, took 4%, and the person who actually ran the exchange took a spread on top of that. Set against what the others earned, A's share was plainly far too small to represent the reward for joining a crime at the risk of severe punishment.
Third, we highlighted that A's conduct was the opposite of someone trying to conceal a crime. A transacted using a corporate account and exchanged business registration certificates — readily traceable — which is not what someone covering their tracks would do. Moreover, after the investigation began, another party involved pressed A to "dress the transactions up as 'gold investment,' forge a contract and give a false account," and A firmly refused and told the truth. Changchun obtained the record of that refusal as well, supporting the conclusion that A had been above board from the start.
The investigating authorities ultimately issued a decision of non-referral in A's case — meaning the matter was closed without being sent to the prosecution — and A was cleared of the serious allegation of involvement in voice phishing. Anyone can be used for a crime without knowing it, and once suspicion falls, saying "I didn't know" is rarely enough. What matters is proving that state of mind step by step through objective facts: how the transactions came about, what was paid, and how the person behaved. Outcomes depend on the facts of each case and may differ, which is exactly why gathering the record early and building a strategy matters so much.