Timor-Leste has become the latest target of organized crime groups using foreign direct investment (FDI) to establish scam centers and illicit gaming operations, according to a new report from the United Nations Office on Drugs and Crime (UNODC).

The Special Administrative Region of Oecusse-Ambeno (RAEOA)—particularly its Oecusse Digital Centre (ODC) free trade zone—has shown regulatory vulnerabilities that criminals appear to be exploiting under the guise of legitimate investment.

This targeting comes amid a broader regional shift following the Philippines’ ban on Philippine Offshore Gaming Operations (POGOs) in July 2024. During a state visit in October 2024, Philippines Justice Secretary Jesus Crispin Remulla warned Timor-Leste officials about potential POGO relocation, citing reports that the country could become a destination for displaced offshore gaming operations.

Signs of infiltration

According to the UNODC, Timor-Leste has already seen concrete signs of infiltration. On August 25th, 2025, law enforcement agencies searched a hotel in RAEOA, seizing multiple SIM cards and Starlink devices—key indicators of online scam centers across Southeast Asia. Authorities are still investigating whether the workers found onsite were coerced victims or active participants, though several had advanced IT qualifications, which UNODC described as evidence of ‘a growing professionalization in parts of the region’s scam centre industry.’

The report links the hotel and related enterprises to a wider network of shell companies and offshore ventures tied to gambling operations in Cambodia. UNODC found overlapping directorships between companies managing hospitality businesses in Oecusse, Dili, and the ODC, raising red flags about corporate structures designed to obscure illicit activity.

One key player is “Tech Company A,” selected to lead RAEOA’s National Digital ID project. Its chairman was convicted in Singapore in 2024 for conspiring to acquire stolen personal data from a Chinese cybercrime syndicate—data intended for online scams and gambling. Despite serving a custodial sentence and being barred by the Isle of Man Gambling Supervision Commission, the chairman retains indirect links to RAEOA’s projects through a web of affiliated companies.

Links to triads and “Broken Tooth”

The UNODC report highlights direct connections between criminal entities in Timor-Leste and notorious transnational organized crime groups. It identifies links to the 14K Triad, including Wan Kuok-koi, better known as “Broken Tooth,” a former Macau gangster whose gambling and junket ventures have long intersected with illicit finance across Southeast Asia.

The network operating in Timor-Leste is also tied to Cambodian casino operators implicated in money laundering and online fraud, as well as to businesses controlling dozens of suspicious gambling domains. UNODC warns that these structures mirror those seen in Cambodia’s Sihanoukville and Myanmar’s Myawaddy—both of which became hubs for human trafficking, cyber-enabled fraud, and illicit gambling.

‘Once infiltrated by organized crime, these jurisdictions often become hubs for cyber fraud, drug trafficking, and human trafficking,’ the UNODC stated, drawing parallels to early developments in the Philippines and the Mekong region.

A broader trend

The infiltration of Timor-Leste reflects a broader trend in which organized crime groups use shell companies, professional service providers, and citizenship-by-investment schemes to conceal their activities. Many individuals linked to suspicious companies in Timor-Leste hold multiple passports—sometimes as many as five—making it easier to evade law enforcement and manipulate identity systems.

These tactics, combined with complex corporate layering across jurisdictions, enable criminal groups to integrate illicit proceeds into the formal economy while avoiding accountability. ‘Organized crime groups engage professionals, including lawyers, accountants, and corporate service providers, who possess specialized knowledge of legal and financial systems,’ the report noted, underscoring how these actors may be exploited—whether knowingly or unknowingly.

Risks ahead as Timor-Leste joins ASEAN

The timing of these developments is especially significant, as Timor-Leste prepares to join the Association of Southeast Asian Nations (ASEAN) in October 2025. UNODC warned that the infiltration of RAEOA and its digital infrastructure ‘poses a serious security risk,’exposing weaknesses in personal data protection and threatening trust in the country’s digital governance systems.

With parallels to past criminal expansions in Cambodia, Laos, and the Philippines, the report stresses that Timor-Leste risks becoming the next hub for transnational crime if urgent regulatory action is not taken.