Daigou Networks

Daigou networks involve individuals or small agencies who purchase goods (often luxury or popular items) abroad using illicit funds, then ship or transport them into the target market—commonly China. By reselling these items domestically, criminals convert illicit capital into seemingly legitimate commercial revenue, effectively integrating the proceeds. This approach frequently circumvents capital controls and import restrictions by exploiting surrogate shoppers and informal shipping methods, thereby obscuring beneficial ownership and reducing AML transparency. In some cases, individuals act as straw buyers or money mules, purchasing high-demand goods on behalf of clients in China while concealing the true source of funds. Investigations have shown a structured, trade-based methodology: after generating proceeds (e.g., from drug sales) in foreign markets, funds are funneled through bank accounts in Southeast Asia, pooled outside the formal banking system, and used by daigou coordinators to pay surrogate shoppers in cash. These shoppers acquire large quantities of consumer items, which are then packaged and shipped to affiliated partners for sale in the receiving jurisdiction, enabling the launderers to realize profits while frustrating standard oversight. Although daigou activity itself may seem entrepreneurial in certain contexts, these networks can blur the line between legitimate cross-border retail and money laundering, complicating efforts to detect and disrupt illicit capital flows.

[
Code
T0013.006
]
[
Name
Daigou Networks
]
[
Version
1.0
]
[
Risk
Channel Risk, Jurisdictional Risk
]
[
Created
2025-02-10
]
[
Modified
2025-04-02
]

Buy on Behalf of

Surrogate Shopper

Grey Market Sales

Shopping Surrogate Networks

Tactics

ML.TA0006
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Using Daigou to initially introduce illicit cash into the formal economy by purchasing goods abroad.

ML.TA0007
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Daigou coordinators employ multi-step cross-border transactions, including pooling funds outside formal banking channels and paying surrogate shoppers in cash. This deliberately obscures the money trail and distances illicit proceeds from their source.

Risks

RS0003
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Channel Risk
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In addition to exploiting cross-border regulatory gaps, daigou networks use informal or surrogate-based channels (e.g., private couriers, undeclared shipments, straw buyers) to bypass standard banking and customs documentation. This secondary vulnerability reduces transparency and impedes the tracking of financial flows and goods.

RS0004
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Jurisdictional Risk
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Daigou networks primarily exploit mismatched regulatory regimes and capital controls across borders. By leveraging differences in AML enforcement and import restrictions between jurisdictions, they obscure beneficial ownership and conceal cross-border value transfers. This core cross-border vulnerability is central to their operations.

Indicators

IND00762
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High frequency and volume of cross-border transactions involving luxury items or high-demand consumer products that exceed normal personal consumption patterns.

IND00763
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Frequent use of multiple shipping addresses or varying beneficiary names linked to the same account, complicating identification of actual recipients or final destinations.

IND00776
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Large cash deposits from unidentified or suspicious sources quickly followed by wire transfers to overseas recipients, potentially for high-demand consumer goods purchases.

IND00810
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Individuals making frequent purchases of the same items, especially luxury goods.

IND00811
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Sudden spikes in incoming funds from diverse payers followed by large outgoing transfers.

IND00829
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Transfers referencing the purchase of goods on behalf of 'friends' or 'clients' with no formal business arrangement.

IND00830
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Frequent reliance on unregistered or informal couriers or shipping methods for large quantities of consumer goods with minimal or no declared documentation.

IND00857
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Usage of personal or low-volume accounts to settle large overseas import purchases for consumer goods, lacking relevant business profiles or documentation.

Data Sources

Encompasses official import and export data, shipping routes, and related customs documentation, illuminating:

  • Frequent use of informal or unregistered couriers for large quantities of consumer goods.
  • Multiple shipping addresses or varying beneficiary names tied to the same entities.

These details allow AML teams to correlate irregular goods movements, repeated shippers, and declared values, revealing high-risk patterns consistent with Daigou networks.

Provides comprehensive financial transaction records, enabling the detection of the following Daigou-related red flags:

  • Repeated or large-volume purchases of high-value consumer goods, suggesting surrogate shopping on behalf of others.
  • Rapid succession of cash deposits followed by cross-border transfers for suspected luxury goods purchases.
  • Transaction references indicating purchases ‘on behalf of friends or clients’ without formal business arrangements.

This data supports investigators in identifying unusual spending patterns, layered transactions, and potential straw buyer activities linked to Daigou networks.

Includes official bills of lading, invoices, and customs declarations for imported goods, enabling:

  • Verification of declared values, item types, and quantities against financial transactions for potential misrepresentation.
  • Detection of repeated shipments of high-demand consumer goods exceeding normal personal usage.

This documentation helps investigators confirm whether import activities align with legitimate trade or mask Daigou-facilitated laundering.

Contains verified customer identities, personal/business details, and beneficial ownership information, helping detect:

  • Discrepancies between stated personal profiles and high-volume commercial-like purchasing or shipping activities.
  • Potential straw buyers or surrogate shoppers misrepresenting their actual source of funds.

Using KYC data helps confirm whether clients’ payment volumes and cross-border import expenses align with their declared profiles, aiding AML investigations into Daigou operations.

Captures details of cross-border payment flows and correspondent banking relationships, helping identify:

  • Rapid transfers of pooled funds from multiple sources to overseas accounts for high-value goods purchases.
  • Patterns of rotating beneficiary accounts distributing payments for suspected Daigou shipments.

Analysts can detect unusual inflows and outflows indicative of money laundering through surrogate shopping or unregistered trade channels.

Mitigations

Perform in-depth background checks on personal or small-business accounts that regularly purchase and import large quantities of consumer goods from overseas. Confirm the legitimacy of their cross-border supply chain, verify shipping channels, and validate the declared end-use of goods. Assess whether transaction volumes match the customer’s stated business or personal profile to detect potential Daigou operations concealing illicit funds or bypassing capital controls.

Set up targeted parameters to flag personal or low-volume accounts that suddenly process larger or more frequent cross-border transactions involving high-demand goods. Investigate patterns such as large incoming cash deposits promptly followed by overseas payments for merchandise, which can be indicative of Daigou networks converting illicit funds into repackaged consumer products.

Proactively communicate with personal shoppers, small-scale Daigou operators, and their customers about import regulations, customs duties, foreign exchange rules, and the risks of inadvertently facilitating money laundering. Encourage transparent disclosure of purchase volumes and origins of funds to reinforce compliance with cross-border transaction requirements.

Review public advertisements on social media platforms (e.g., WeChat, Weibo, Instagram, Xiaohongshu) that claim to offer bulk or recurrent shopping services. Compare these findings with the customer's actual transaction and shipping data to uncover large-scale Daigou operations disguised as personal, small-volume purchases.

Examine shipping documents, invoices, and declared product details for cross-border consumer goods. Identify unusually high-volume or repetitive shipments that are inconsistent with personal use and correlate them with payment flows to reveal Daigou schemes funneling illicit funds through commercial-like transactions.

Instruments

  • Illicit funds are funneled into bank accounts in Southeast Asia to pool proceeds outside of direct scrutiny.
  • From these accounts, criminals withdraw cash or conduct transactions to purchase goods, masking the original source of funds.
IN0051
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  • Daigou coordinators directly pay surrogate shoppers with physical cash to avoid formal financial channels.
  • This reliance on cash transactions obscures the fund trail, reduces AML oversight, and facilitates the bulk purchasing of goods with illicit proceeds.
IN0053
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  • Daigou shoppers acquire high-value items (e.g., designer handbags, exclusive electronics) abroad using illicit funds.
  • Reselling these items locally transforms illegal proceeds into legitimate-appearing commercial revenue, circumventing capital controls and standard AML checks.

Service & Products

  • Criminals use online marketplaces to resell luxury or high-demand items bought with illicit funds, presenting them as ordinary retail transactions.
  • These sales effectively integrate illegal proceeds into legitimate-appearing revenue streams, masking the original criminal source of the money.
  • Daigou coordinators exploit small-parcel or informal courier shipping to move consumer goods purchased with illicit funds across borders.
  • Under-declared values, incomplete shipping documentation, or multiple recipient addresses obscure beneficial ownership and frustrate AML oversight.

Actors

Criminals channel illicit proceeds into foreign accounts and pay daigou coordinators or surrogate shoppers in cash to buy luxury goods abroad. Reselling these items at home integrates criminal proceeds into legitimate commerce, masking their origin.

AT0076
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Individuals act as straw buyers or mules by receiving illicit funds to purchase high-demand items abroad on behalf of daigou coordinators. This arrangement distances the launderers from direct scrutiny, making it harder for financial institutions to trace the illicit source of funds.

References

  1. APG (Asia/Pacific Group on Money Laundering). (2021, July). APG Yearly Typologies Report 2021. Asia/Pacific Group on Money Laundering. https://apgml.org/documents/default.aspx

  2. FINTRAC (Financial Transactions and Reports Analysis Centre of Canada). (2023). Updated indicators: Laundering the proceeds of crime through underground banking schemes.FINTRAC. https://fintrac-canafe.canada.ca/intel/operation/ml-rec-eng