Combest ex-executives pay HK$192m to shareholders under SFC settlement; disqualified 8 to 12 years
Combest Holdings Limited · Listed GEM company
The case in brief
Visible before detection
Checks that could have surfaced it, on hindsight
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.
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.
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.
Same pattern
A summary of public documents. It reports what the sources say. It is not Kubr's finding and not a statement of guilt.