KUBR

Combest ex-executives pay HK$192m to shareholders under SFC settlement; disqualified 8 to 12 years

Combest Holdings Limited · Listed GEM company

Related-party diversionRevenue inflation

The case in brief

Visible before detection

    Checks that could have surfaced it, on hindsight

    1

    Ownership / related-party links

    Ownership checks would link the revenue sources and loan counterparties to the shadow director.

    Can mislead when: Nominee directors and offshore layers hide links. Name matching throws up false positives, so every flag shows its evidence path.

    2

    End-use tracing of funds

    End-use tracing would show interest and fee payments flowing to connected entities.

    Can mislead when: Kubr sees only the company's own accounts. Once money reaches a third party's bank, Kubr can flag the payee but cannot see the next hop without that party's consent.

    3

    Avoidance transactions

    A valuation review of the 2016 and 2017 acquisitions would show prices well above worth.

    Can mislead when: Only the tribunal decides what counts as an avoidance transaction. Kubr flags candidates and never states a conclusion.

    Where Kubr services would have helped

    Valuation context

    Offered in India
    • Peer multiples and the exit-multiple bridge would have shown how much of the story relied on valuation holding.

    Borrower monitor

    Offered in India
    • C3 Ownership checks would link the revenue sources and loan counterparties to the shadow director.
    • C6 End-use tracing would show interest and fee payments flowing to connected entities.

    Proceeds tracer

    Offered in India
    • C3 Ownership checks would link the revenue sources and loan counterparties to the shadow director.
    • C6 End-use tracing would show interest and fee payments flowing to connected entities.

    Verified Snapshot

    Offered in India
    • C3 Ownership checks would link the revenue sources and loan counterparties to the shadow director.

    Mapped from the checks each service runs. A hindsight reading of public records, not a promise that the failure would have been found.

    A summary of public documents. It reports what the sources say. It is not Kubr's finding and not a statement of guilt.