High-Value Fraud Involving Fake Promises of Internal Channels for Expedited ODI Filing and Overseas Expansion

Who Gets Targeted

The primary victims are small and medium-sized foreign trade enterprise owners, cross-border e-commerce sellers, and novice entrepreneurs attempting overseas investment for the first time who are eager to expand into overseas markets but lack professional cross-border compliance teams. They generally lack an in-depth understanding of the latest regulatory policies on overseas investment. Coupled with the pressing psychological pressure brought by business expansion windows, they are extremely eager to quickly obtain compliance passes to avoid missing orders. These victims often blindly trust the internal channels and pass-guaranteed or refund-guaranteed sales pitches claimed by the agency. Without verifying the agency's qualifications and true background, they sign contracts and pay large deposits. Once the scam is exposed, not only do they lose hefty agency fees, but they also face the risk of regulatory non-compliance penalties.

骗局怎么运作

• Relying on search engines and industry communities to precisely target enterprise owners eager to expand overseas, the agency claims to be a professional overseas expansion compliance consulting service platform. The webpage is stuffed with keywords such as real-time filings and successful case displays, forging government endorsements or affiliations with well-known law firms. Standard sales pitches emphasize that new regulations have made approvals extremely strict and self-operation easily leads to rejection, whereas the agency possesses years of practical experience and can access internal expedited channels to obtain certificates in as fast as three days.
• Sales representatives impersonate consulting advisors to proactively call target enterprises, leveraging enterprises' unfamiliarity with the overseas investment filing process to conduct a dimensionality reduction strike via information asymmetry. They meticulously compare the tedium of traditional self-filing with the stringent requirements under the new regulations, deliberately creating panic and anxiety that failing to use an agency will result in getting stuck in approval bottlenecks or funds being legally unable to leave the country, thereby forcing business owners to abandon the idea of independent application.
• Inducing clients to sign service contracts online that feature harsh standard terms and plenty of disclaimer clauses, collecting exorbitant lump-sum deposits or full agency fees ranging from tens of thousands to hundreds of thousands of yuan. They claim the fees include multi-department lobbying fees and expedited service fees, promising a full refund if unsuccessful; however, the contract clauses hide various stringent pre-conditions for refunds that are difficult to achieve, laying the groundwork for subsequently reneging on debts.
• After receiving the funds, the agency adopts delaying tactics, only allowing clients to prepare basic materials themselves while providing no substantive professional guidance or compliance review throughout the process. When clients urge them for progress updates, they repeatedly stall using excuses such as recent strict regulatory inspections by authorities, system upgrades, or documents still undergoing internal review. Some fraudsters even forge fake acceptance receipts or digitally manipulated approval screenshots to win trust.
• When clients give up on their own or request a refund due to the prolonged failure to obtain legitimate overseas compliance credentials, the agency either directly goes out of contact or refuses the refund based on prior hidden clauses. Some extreme agencies even directly deregister and run away while blocking the clients. Not only do enterprises suffer financial losses, but the unreviewed compliance materials they submitted earlier may also face regulatory accountability for non-compliance.

红旗信号（看到这些快跑）

• 🚩 Promising guaranteed approval, internal expedited channels, and 100% certificate issuance. Regular overseas investment filing approvals are strictly reviewed in accordance with the law by the National Development and Reform Commission (NDRC) and the Ministry of Commerce; no special internal channels exist.
• 🚩 Contracts contain a large number of standardized disclaimer clauses, and refund promises are only honored verbally without being explicitly written into the agreement or setting pre-conditions for refunds that are virtually impossible to trigger.
• 🚩 The corporate account name does not match the contracting party named in the contract, or clients are requested to transfer agency fees to personal accounts or unknown third-party shell company accounts.
• 🚩 Sales representatives frequently use high-pressure tactics during communications—such as claiming new regulations are strictly enforced or funds won't get out unless processed immediately—to manufacture time-related anxiety and panic to urge payment.
• 🚩 Refusing to present verifiable past successful cases and authoritative qualification proofs, with so-called successful cases failing to be verified on official enterprise credit information publicity systems or relevant regulatory inspection platforms.

真实案例

• In 2026, the public security department of a certain city reported a fraud case disguised as cross-border overseas expansion compliance agency services: A criminal gang led by an individual surnamed Jia registered a shell consulting company to post advertisements on social platforms offering proxy services for overseas investment filings, falsely claiming to have NDRC internal expedited channels. Within a few months, over a dozen enterprises paid hefty agency fees before Jia's gang directly cut off contact, with the involved amount exceeding one million yuan.
• In March 2026, according to media reports, a cross-border e-commerce boss surnamed Yi trusted an agency's all-inclusive service promise and paid an 80,000-yuan deposit to commission them for handling overseas expansion compliance procedures. Half a year passed with zero progress, and the refund request was rejected on the grounds of incomplete material preparation. Subsequent investigations revealed that the agency completely lacked legal and compliant consulting qualifications.
• In May 2026, a female foreign trade enterprise owner searching online for overseas expansion compliance agency services was duped by an agency claiming that self-operation after the implementation of new regulations would easily result in getting stuck, paying a 50,000-yuan deposit. She later discovered that the acceptance receipt issued by the agency was a forged image. After reporting it to the authorities, the police confirmed it was a contract scam under the guise of overseas expansion agency services.
• In September 2026, the Futian Branch of the Shenzhen Municipal Public Security Bureau reported the dismantling of a fraud syndicate operating under the guise of 'title appraisal proxy services': The involved cultural communication company and affiliated educational technology company possessed no educational licensing training qualifications or professional title evaluation qualifications, yet they signed 'harsh term' contracts with victims under the names of 'high pass rates' and 'internal channels'. After collecting fees, they delayed processing. Individual victims were defrauded of amounts ranging from 9,000 yuan to 208,000 yuan, and 51 suspects were apprehended. (Source: [https://gdga.gd.gov.cn/jmhd/xwfb/content/post_4953310.html](https://gdga.gd.gov.cn/jmhd/xwfb/content/post_4953310.html))
• In April 2026, the People's Court of Shunyi District, Beijing, sentenced a contract fraud case disguised as private outbound travel services: The principal offender and others forged qualification materials to package the intermediary's image when the company lacked the operational qualifications for external labor cooperation. They defrauded intermediary fees totaling over 9 million yuan under the pretext of signing service contracts. The principal offender was sentenced to 13 years in prison and fined 200,000 yuan. (Source: [https://m.thepaper.cn/newsDetail_forward_33069001?commTag=true](https://m.thepaper.cn/newsDetail_forward_33069001?commTag=true))

Official Stance

• On April 15, 2026, public security and education departments jointly issued an early warning titled 'Beware of Falling into the Trap of Proxy Overseas Labor Export Fraud', reminding the public to be alert to new fraud methods where wrongdoers use new cross-border overseas expansion regulations and high-paying overseas recruitment as pretexts to collect high agency fees and security deposits.
• In August 2026, market supervision bureaus across multiple regions and the cross-border compliance circle jointly issued the 'Guidelines on ODI Full-Process Supervision and Compliance Essentials after the Implementation of Order No. 837', explicitly pointing out that formal overseas expansion compliance approvals have no accelerated special channels and reminding enterprises not to blindly trust fraudulent agencies claiming internal expedited capabilities.
• On March 27, 2026, judicial authorities in various regions issued anti-fraud warning notifications, calling out cases where cross-border telecommunications fraud syndicates disguised themselves as professional rights-protection lawyers, reminding the public and overseas-expanding entities to choose regular legal and compliance service providers and avoid transferring money privately to unqualified accounts.

How to Protect Yourself

• ✅ Verify business licenses and agency qualifications: Before signing a contract, cross-check the entity registration information of the agency on the National Enterprise Credit Information Publicity System, focusing on administrative penalties and abnormal operation directories. Log into the official websites of local development and reform commissions and commerce departments to query regular filing processing guidelines, and do not blindly trust promises of internal connections.
• ✅ Reject payments to personal accounts: Any agency fee payments must be remitted to the corporate bank account of the agency matching the contracting party in the contract. Resolutely refuse to transfer funds to personal accounts or irrelevant third-party shell company accounts, and keep complete transfer vouchers.
• ✅ Scrutinize contract refund clauses: Do not listen to verbal promises. Full refunds for unsuccessful processing must be written in black and white into the contract. Carefully review pre-conditions for refunds and remove obviously unreasonable disclaimers and harsh terms.
• ✅ Consult official channels independently: When intermediaries use new regulations to manufacture approval anxiety, enterprises can directly call the business service windows of local government administration bureaus or development and reform commissions to consult on real progress and material requirements, avoiding being harvested through information asymmetry.