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Round-tripping at Trek 2000 and how it was uncovered Nov 27, 2007 — T-Data Systems (S) is incorporated; 100% owned by Loo Soo Hooi, wife of Poo Teng Pin. Poo was group director of R&D and executive director at Trek 2000 International from May 24, 2006 to July 12, 2016. April 30, 2008 — Henn Tan, Trek chairman, CEO and executive director, becomes sole shareholder of S-Com Solutions (Hong Kong) Co. Interviews and reviews of documents conducted by RSM Corporate Advisory suggest that affairs at S-Com HK were handled by Trek employees. May 31, 2011 — Trek Technology (Singapore) sells US$135,000 worth of merchandise to S-Com HK. On Jan 11, 2012, S-Com HK sells what may be the same batch of stocks to Trek Technology (HK) Co for US$400,000. Assuming the transaction is for the same batch of stocks, S-Com would have earned US$265,000, or a 196.3% profit margin. Four other similar transactions are recorded involving S-Com HK and various units of Trek. In total, S-Com appears to have earned US$266,214.38 from the transactions. July 7, 2011 — S-Com System (S), a unit of Trek, makes a payment to Tan’s bank account. The payment is associated with an invoice for purchases made by Trek from Key Asic. Sept 18, 2012 — Wayne Tan Joon Yong, Tan’s son, becomes owner of 80% of T-Data Sept 30, 2013 — Trek Singapore sells US$18,000 worth of merchandise to T-Data. On Oct 14, T-Data sells what appears to be the same batch of stocks to Cloud Stringers (S), a unit of Trek, for US$20,250. Assuming the transaction is for the same batch of stocks, T-Data would have earned US$2,250, or a 12.5% profit margin. Three other similar transactions are recorded involving T-Data and various units of Trek. In total, T-Data appears to have earned US$4,699.20 from the transactions. Between Nov 12, 2012 and Nov 28, 2014, there were 287 sets of transactions conducted among Trek Singapore, T-Data and Trek Technology (Thailand) Co. T-Data appears to have earned US$1,701.31 from these transactions. Oct 15, 2013 — Trek Singapore sells US$592,070.44 worth of components to Party B1. On Nov 14, it sells another US$558,824.13 worth of Toshiba NAND flash to the same party — for a total transaction value of US$1.15 million. March 26, 2014 — Wayne transfers his 80% stake in T-Data to his cousin, Edwin Tan Chun Chieh May 30, 2014 — Trek Singapore buys US$1.15 million of stocks from Party B1. RSM flags this as suspicious because the letterheads of the invoices issued by Party B1 carry the address of Trek HK’s office. Also, the transactions were booked, unusually for transactions with Party B1, as cash transactions. And Trek has no history of purchasing any stocks or goods from Party B1. Individuals interviewed by RSM claim to have no knowledge of the nature and composition of the stocks sold by Trek to Party B1 or those bought by Trek from Party B1. Trek is unable to contact Party B1. Similarly suspicious transactions are recorded with Parties B2 and B3. Aug 1, 2014 — Winn Tan Joon Wei, Tan’s son, is employed as senior sales manager at T-Data with a monthly salary of $3,000 Jan 1, 2015 — Edwin is employed as sales executive at T-Data with a monthly salary of $2,000 Feb 1, 2015 — Lydia Tan Li Ping, Tan’s daughter, is employed as accounts executive at T-Data with a monthly salary of $2,000 March 24, 2015 — Shirley Tan Ai Ching, another cousin of Wayne’s, subscribes for new shares in T-Data, resulting in Loo’s shareholding being diluted to 0.2% June 26, 2015 — Poo signs and confirms on an order requisition form for Unimicron Technology. The order is valued at US$3.2 million. The sale is later discovered to be to Colite Technology instead. Payment for the goods was made by S-Com HK and Tan. Trek Singapore later returned these funds to S-Com HK and Tan. Feb 25, 2016 — Trek announces that its audit committee has found certain interested party transactions between Trek and T-Data dated from November 2007 to March 2014 March 18, 2016 — Shirley buys Loo’s shares in T-Data April 26, 2016 — Trek announces that its independent auditors Ernst & Young have submitted a report to the Accounting and Corporate Regulatory Authority on matters that came to EY’s attention. May 25, 2016 — Trek says its chief financial officer and executive director, Gurcharan Singh, is assisting the Commercial Affairs Department (CAD) of the Singapore Police Force April 7, 2016 — Trek’s audit committee appoints TSMP Law Corp to review the transactions between T-Data and Trek June 1, 2016 — Trek discloses that Poo, Tan and regional sales president, Foo Kok Wah, are assisting the CAD June 8, 2016 — Trek appoints RSM as forensic accountants to review any interested party transactions Sept 21, 2016 — EY says it is unable to obtain sufficient audit evidence to provide a basis for an audit opinion for FY2015 ended December May 29, 2017 — EY issues another disclaimer of opinion, citing lack of audit evidence available July 18, 2017 — RSM releases report on Trek’s interested party transactions. It is revealed that T-Data has transacted sales with Trek worth US$185.7 million; S-Com Solutions HK has transactions worth US$11.3 million. Sept 8, 2017 — RSM identifies round-tripping interested party transactions between Trek and its subsidiaries. April 23, 2018 — Trek releases 297-page forensic accountant’s report, with evidence that Tan and Singh were involved in suspicious transactions and round-tripping that caused overstatement of revenue, phantom sales and altering of invoices that aimed to increase Trek’s income. Trading halts but resumes later in the day. Trek holds AGM.
