Recently, the incident of actor Wang Xing being kidnapped in Thailand and taken to a crime park in Myawaddy, Myanmar, has been widely discussed online. Although it appears to be an isolated case, Wang Xing is just one representative of countless victims. The vast number of victims behind this incident, as well as the numerous telecom fraud victims it has spawned domestically, highlight the current shortcomings in China’s efforts to protect its overseas interests and combat foreign-related crimes. Following the incident, netizens have been outraged, demanding that the government take strong action against such overseas crime syndicates. Here, I will briefly analyze how to effectively combat these criminal activities.
The Rampant Overseas Park-Style Crime Syndicates
Online sources have compiled a list of the larger overseas crime parks, numbering around fifty to sixty. Myanmar, with its large-scale operations, ranks first, with dozens of parks densely distributed along the thousands of kilometers of border in northern and eastern Myanmar.
Myanmar: Meng Neng 51 Villa Park, Meng Neng Sanzheng Erqu, Boggan Sheng Yuan Park, Shengyuan Park, Wohu Mountain Villa Weisheng Park, Rose Garden, Laojie Dongcheng Fusheng Technology Park, Muse COD Park, KK Park Phase I & II, Dongfeng Park Phase I & II, Century City Park, OK Park, Phoenix Park, Hengsheng Phase I & II, Jiaoke Village Taichang Park, UK Park, Tongda Park, Xinghua Park, Baoli Park, Dongmei Park, Jinxin Park, Yalong Bay Park, Xinghe Park, Apollo Park, Asia-Pacific City Park Phase I & II, Yulong Bay Park, Mengbo Telecom Technology Park, Daqili Fuxing Park, Youhua Park. Cambodia: Phnom Penh Yong Sheng Road Brothers Park, Sihanoukville Golden Port Park, Qixinghai Park, Bodhi Park, Sihanoukville Golden Fortune 5 Park, Sihanoukville Bokai Park, New Huang Le Park, Triumph City Park, Phnom Penh Sang Park, Jinshui Park, Kandal Province Pacific Park. Dubai, UAE: DIC Park, DIP Park, Wynn Park, Phoenix Park. Thailand: Baliya Brilliant District, Bangkok Villa District, Mae Sot and Chumphon residential areas. Philippines: Manila Sun City Park, Cavite Park. Laos: Vientiane City Park, Tangren International Park. Indonesia: Surabaya Park. Malaysia: Kuala Lumpur Park.
According to a report released by the Office of the United Nations High Commissioner for Human Rights in August 2023, 120,000 people in Myanmar are forced to engage in telecom fraud, and 100,000 in Cambodia. The crimes committed in these parks are too numerous to mention, and the entire second, third, fourth, fifth, and sixth chapters of the Criminal Law may not be sufficient to cover them all. Since the inception of China’s Criminal Law, there has never been a situation where so many laws could be violated simultaneously with impunity. These crime parks are not just challenging the Criminal Law; they are trampling on the dignity of the entire nation.
- Crimes Endangering Public Safety: Including organizing, leading, or participating in terrorist organizations, aiding terrorist activities, preparing to commit terrorist activities, illegal manufacturing, trading, transporting, mailing, or storing firearms, ammunition, explosives, illegal manufacturing, trading, transporting, or storing hazardous materials, illegal manufacturing or selling firearms, theft or robbery of firearms, ammunition, explosives, or hazardous materials, illegal possession or concealment of firearms or ammunition, illegal lending or renting of firearms, illegal carrying of firearms, ammunition, controlled knives, or hazardous materials endangering public safety, etc.
- Crimes Disrupting Market Economic Order: Including smuggling weapons, ammunition, nuclear materials, counterfeit currency; smuggling goods or items prohibited from import or export by the state; smuggling ordinary goods or items; armed smuggling; obstructing liquidation; concealing or intentionally destroying accounting documents, books, or financial reports; bribery of non-state personnel; bribery to non-state personnel; bribery to foreign public officials or international public organization officials; counterfeiting currency; unauthorized establishment of financial institutions; forging, altering, or transferring financial institution business licenses or approval documents; usury; fraudulently obtaining loans, bill acceptance, or financial instruments; illegal absorption of public deposits; forging or altering financial instruments; obstructing credit card management; stealing, buying, or illegally providing credit card information; money laundering; fundraising fraud; credit card fraud; theft; tax evasion; infringement of trade secrets; stealing, spying, buying, or illegally providing trade secrets for foreign entities; contract fraud; organizing or leading pyramid schemes; forced transactions, etc.
- Crimes Infringing on Citizens’ Personal Rights and Democratic Rights: Including intentional homicide; negligent homicide; intentional injury; organizing the sale of human organs; negligent causing of serious injury; rape; forced indecency or insult; indecent assault on children; illegal detention; kidnapping; trafficking of women or children; buying trafficked women or children; rape; illegal detention; insult; obstructing official duties; gathering to obstruct the rescue of bought women or children; forced labor; insult; defamation; inciting ethnic hatred or discrimination; infringing on freedom of communication; infringing on citizens’ personal information, etc.
- Crimes Against Property: Including robbery; theft; fraud; snatching; gathering to snatch; embezzlement; extortion; intentional destruction of property; refusal to pay labor remuneration, etc.
- Other Crimes: Including illegal intrusion into computer information systems; illegal acquisition or control of computer information system data; providing tools for intrusion or illegal control of computer information systems; using false identity documents or stealing identity documents; impersonation; forging, altering, or trading official documents, certificates, or seals of state organs; theft, snatching, or destruction of official documents, certificates, or seals of state organs; forging seals of companies, enterprises, institutions, or people’s organizations; forging, altering, or trading identity documents; provoking trouble; collecting illegal debts; teaching criminal methods; gambling; running gambling dens; organizing or participating in gambling abroad; obstructing testimony; aiding in the destruction or forgery of evidence; retaliating against witnesses; harboring or shielding criminals; concealing or disguising criminal proceeds; organizing illegal border crossings; transporting illegal border crossers; illegal border crossing; illegal organization of blood sales; forced blood sales; illegal medical practice; smuggling, selling, transporting, or manufacturing drugs; harboring drug criminals; concealing, transferring, or disguising drugs or drug proceeds; inducing, instigating, or deceiving others into drug use; forcing others to use drugs; organizing prostitution; forced prostitution; assisting in organizing prostitution; producing, copying, publishing, selling, or disseminating obscene materials for profit, etc.
The above crimes are just a brief list, and most of them are more or less related to overseas crime parks. (There may be some errors.)
Current Measures to Combat Overseas Park-Style Crime Syndicates
In recent years, China has treated these overseas park-style crime syndicates as ordinary crimes, with the public security authorities leading international law enforcement cooperation, achieving some success. The most significant achievement has been the complete eradication of crime parks in the China-Myanmar border area.
China News Network: At a press conference held by the Ministry of Public Security on January 10, spokesperson Zhang Ming announced that by the end of 2024, more than 53,000 Chinese nationals involved in fraud had been arrested, and the notorious “Four Families” crime syndicate in northern Myanmar’s Kokang region had been completely dismantled. All large-scale telecom fraud parks near the China-Myanmar border in northern Myanmar have been eradicated, marking a significant milestone in the special operation, which has led to a sharp decline in the number of telecom fraud cases and losses nationwide. Currently, the cases involving the “Four Families” crime syndicate are gradually entering the litigation phase. (January 10, 2025)
International Law Enforcement Cooperation
International law enforcement cooperation is a relatively new concept in China, and before 2010, it was one of the least prioritized areas in foreign-related work. As I mentioned in my previous article Why Should We Encourage Zhejiang University Graduates to Study Law Abroad, the development of foreign-related legal affairs in China has been slow:
China joined the WTO in 2000, and before that, domestic laws were almost entirely disconnected from the world. Even after joining the WTO, domestic legal education primarily focused on domestic law, with international law and private international law being barely touched upon. When I was in university, my professors bluntly stated that these subjects would be of no use to students in the future, and we could just skim through them. This has indeed been the case, as in the more than 20 years since joining the WTO, China’s foreign-related legal affairs have made little progress, severely lagging behind economic development.
The same is true for foreign-related law enforcement. In a 2017 Xinhua article on the achievements of China’s public security authorities in international law enforcement cooperation, the most notable achievement mentioned was the successful crackdown on the Naw Kham armed group, which killed 13 Chinese sailors on the Mekong River. The article also mentioned that “in 2016, China collaborated with more than 10 countries in Southeast Asia, Africa, and Europe to combat telecom fraud, dismantling hundreds of criminal dens and arresting nearly 5,000 suspects, effectively curbing the high incidence of such crimes.” However, this achievement was later proven to be just a small step in the fight against telecom fraud. Otherwise, there would not have been the subsequent arrest of 53,000 people in northern Myanmar in 2024.
The 53,000 arrests in northern Myanmar, from today’s perspective, are likely just a small fraction of the total number of people involved in overseas crime parks operating under the guise of telecom fraud. According to earlier data released by Thailand, around 70,000 people are trafficked or lured from Thailand to Myanmar each year. Dubai and the UAE, which have long been neglected, are also said to have crime parks with hundreds of thousands of people. As mentioned in the Ministry of Public Security’s press conference on January 10: “The current crime situation remains severe and complex, with cases still at a high level, and the scale of overseas dens remains large, with many so-called ’technology parks’ and ‘development zones’ providing venues for telecom fraud.”
Limitations of Law Enforcement Cooperation
Although international law enforcement cooperation led by the police has achieved some success, particularly the dismantling of the “Four Families” in northern Myanmar, which has indeed boosted morale, we must also recognize the unique characteristics of northern Myanmar: 1. It is located near the China-Myanmar border, close to China. 2. Chinese culture is the mainstream culture in the region, with some even declaring themselves remnants of old China. 3. The local factional struggles are complex, allowing for a strategy of allying with one group to fight another. These favorable factors may not exist in future efforts to combat crime parks in eastern Myanmar, Cambodia, Thailand, or even the Middle East.
Speed of Action Must Be Fast. One unavoidable issue in cross-border law enforcement cooperation is the risk of “tipping off” the criminals. The situation where most members of local crime syndicates like the “Four Families” in northern Myanmar remain in the area and are eventually arrested may be difficult to replicate in other crime parks. For example, in the article “Spatial Migration Analysis of Transnational Telecom Fraud Crime Agglomeration Areas—A Qualitative Study of the Greater Mekong Subregion Sample” published in the Journal of the People’s Public Security University of China (Natural Science Edition) in 2021, it was clearly stated that “due to the evolution of the political situation, changes in national policies, rising crime costs, and the formation of a ‘confrontation’ between Chinese and Myanmar law enforcement, telecom fraud dens in northern Myanmar may migrate within 5 to 10 years, with Myawaddy becoming a new hotspot for telecom fraud.” This prediction accurately foreshadowed the current wave of attention surrounding the Wang Xing incident, with the only unexpected factor being the speed at which these criminals relocated. Previous incidents in Cambodia also showed that after the Cambodian government issued a “ban on online gambling” in August 2019, 80% of online crime syndicates quickly left Cambodia. The vast rural areas of Myanmar are an ideal destination for such relocations.
Law Enforcement Capabilities Must Be Strong. Currently, China’s efforts to combat overseas crime parks are still confined within the framework of “telecom fraud.” Once defined as “telecom fraud,” only the public security authorities can take the lead in handling it, and in international law enforcement, the police are constrained by various treaties and agreements, often relying on local law enforcement, making independent action almost impossible. In northern Myanmar, it was possible to ally with one group to fight another, relying on the pro-China military government for law enforcement. However, in areas like Myawaddy along the Myanmar-Thailand border, or potentially in the future along the Myanmar-India border or other inland areas, such high levels of cooperation may be difficult to achieve. This is why the public security university journal had already warned years ago that Myawaddy could become a relocation area for northern Myanmar crime syndicates, but no action was taken to prevent it. After all, these areas are dominated by local ethnic groups, and the Myanmar military government has relatively weak control over them. These local warlords are likely to benefit from the crime parks and have little incentive to cooperate with law enforcement. Additionally, racial differences may give rise to nationalist sentiments, making future law enforcement cooperation extremely challenging. For example, according to a 2023 report by the United Nations, crime syndicates in Cambodian parks are estimated to rake in $7.5 to $12.5 billion annually, accounting for half of Cambodia’s GDP.
The Intensity of the Crackdown Must Be Strong. The crimes committed in overseas telecom fraud parks, exemplified by the KK Park in Myawaddy, are heinous, particularly those involving kidnapping, murder, organ trafficking, and enslavement, all of which violate the most basic human moral standards. Under the guise of high-tech parks, these criminals commit the most inhumane acts, akin to the infamous “Unit 731.” If the current approach of arresting and prosecuting a few thousand people is considered civilized, it is far too lenient. Compared to the profits gained from these crimes and the potential criminal liabilities, the more civilized the crackdown, the greater the future risks, and the higher the likelihood of others replicating these criminal methods. Currently, these parks operate under the model of “Chinese defrauding Chinese” or “Chinese kidnapping Chinese,” and as long as the perpetrators can be brought back, domestic law can easily handle them. However, as this criminal model spreads, it is likely that foreigners will begin to imitate it, and by then, even adopting the U.S. approach of “long-arm jurisdiction” may be too late.
Recommendations for Combating Overseas Park-Style Crime Syndicates
Following the Wang Xing incident, countless citizens have called for the classification of overseas crime parks like the KK Park in Myawaddy as terrorist organizations. I personally agree with this view.
Legally Classifying Crime Parks as Terrorist Organizations Faces No Obstacles
According to Article 3 of China’s Counter-Terrorism Law, terrorism is defined as the use of violence, destruction, intimidation, and other means to create social panic, endanger public safety, infringe on personal and property rights, or coerce state organs or international organizations to achieve political, ideological, or other objectives. Violence, intimidation, creating social panic, and infringing on personal and property rights are all typical characteristics of crime parks. These crime syndicates aim to organize, plan, and carry out terrorist activities, resulting in casualties, significant property losses, and severe social disorder. The only potential flaw is that traditional Chinese definitions of terrorism require these crime syndicates to have political or ideological objectives. However, internationally recognized criteria for defining terrorist organizations are not as stringent, and Chinese criminal law also includes phrases like “…and other objectives” or “other terrorist activities,” leaving room for judicial interpretation. Even if a political or ideological objective must be identified, the fact that these crime syndicates have severely disrupted the “Belt and Road” initiative and pose a significant threat to Chinese citizens traveling to Southeast Asia fully satisfies this requirement.
There Are Precedents for Treating Crime Parks as Terrorist Organizations Internationally
Recently, there have been many discussions online, with one of the most notable being Israel’s definition of terrorism. Specifically, any act of kidnapping Israeli citizens outside of Israel is classified as a terrorist activity.Israel can dispatch troops to “pursue and punish no matter how far.” Although this statement may sound a bit exaggerated, it is undeniable that Israel is indeed a pioneer in global counter-terrorism. The world’s first counter-terrorism legislation originated from Israel and has influenced subsequent counter-terrorism laws in various countries, including a series of international conventions and regional agreements under the United Nations framework. After reviewing the United Nations International Instruments Related to the Prevention and Suppression of International Terrorism, I believe there are no significant obstacles in international law to classifying park-based criminal groups as terrorist organizations for targeted action. Treating transnational kidnapping and hostage-taking as counter-terrorism operations has precedents in many countries.
International Convention Against the Taking of Hostages: Article 1 states that any person who seizes or detains and threatens to kill, injure, or continue to detain another person (referred to as a “hostage”) to compel a third party—such as a state, an international intergovernmental organization, a natural or legal person, or a group of people—to act or refrain from acting as a condition for the release of the hostage commits the offense of hostage-taking within the meaning of this Convention. (This convention is one of the five major UN counter-terrorism conventions and is included as an annex in various regional conventions, including those of the Shanghai Cooperation Organization and ASEAN. In China, “hostage-taking” falls under the scope of “kidnapping.”)
European Convention on the Suppression of Terrorism: Article 1 states that for the purpose of extradition between contracting states, none of the following offenses shall be regarded as a political offense or an offense connected with a political offense or an offense inspired by political motives: (d) offenses involving kidnapping, hostage-taking, or serious unlawful detention.
Inter-American Convention to Prevent and Punish Acts of Terrorism: Article 1 states that the contracting states undertake to cooperate among themselves by taking the measures they consider effective, under their own laws, and especially in accordance with the provisions of this convention, to prevent and punish acts of terrorism, especially kidnapping, murder, and other assaults against the lives and personal integrity of those persons to whom the state has the duty to give special protection according to international law, as well as extortion in connection with those crimes.
SAARC Regional Convention on Suppression of Terrorism: Article 1 states that any act constituting the following offenses under the laws of the contracting states shall be regarded as terrorist acts: murder, manslaughter, assault causing bodily harm, kidnapping, hostage-taking, and offenses related to firearms, weapons, explosives, and dangerous substances when used as a means to perpetrate indiscriminate violence resulting in death or serious bodily injury or serious damage to property.
Shanghai Convention on Combating Terrorism, Separatism, and Extremism: Article 1 defines “terrorism” as any act intended to cause death or serious bodily injury to civilians or any other person not actively involved in hostilities in a situation of armed conflict, or to cause significant damage to material targets, as well as the organization, planning, conspiracy, or incitement of such acts, which, by their nature or context, are intended to intimidate the population, undermine public security, or compel governments or international organizations to do or abstain from doing any act, and which are punishable under the domestic laws of the parties.
Shanghai Cooperation Organization Convention on Counter-Terrorism: Article 2 defines “terrorism” as an ideology and practice of violence aimed at endangering the interests of the state, society, and individuals, influencing the decision-making of government authorities or international organizations, and instilling fear through the commission or threat of violence and/or other criminal activities.
Criminal Law of the People’s Republic of China
Article 239: [Crime of Kidnapping] Whoever kidnaps another person for the purpose of extorting property or holds another person as a hostage shall be sentenced to fixed-term imprisonment of not less than ten years or life imprisonment, and shall also be fined or have property confiscated; if the circumstances are relatively minor, the offender shall be sentenced to fixed-term imprisonment of not less than five years but not more than ten years, and shall also be fined. If the offender kills the kidnapped person or intentionally injures the kidnapped person, causing serious injury or death, the offender shall be sentenced to life imprisonment or death, and shall also have property confiscated. Whoever steals an infant or young child for the purpose of extorting property shall be punished in accordance with the provisions of the preceding two paragraphs.
Article 120: [Crime of Organizing, Leading, or Participating in a Terrorist Organization] Whoever organizes or leads a terrorist organization shall be sentenced to fixed-term imprisonment of not less than ten years or life imprisonment, and shall also have property confiscated; whoever actively participates in such an organization shall be sentenced to fixed-term imprisonment of not less than three years but not more than ten years, and shall also be fined; other participants shall be sentenced to fixed-term imprisonment of not more than three years, criminal detention, public surveillance, or deprivation of political rights, and may also be fined. If the offender commits murder, explosion, kidnapping, or other crimes in addition to the offenses mentioned above, the offender shall be punished in accordance with the provisions on combined punishment for multiple crimes.