THE SCIONS OF ROBERT KUOK, THE RICHEST MAN OF MALAYSIA PROVIDED ILLEGAL POLITICAL DONATION TO A YOUNG MEMBER OF PARLIAMENT OF MONGOLIA

Bolormaa Enkhbat, a young Member of Parliament elected from the Western region in 2024 is accused of breaching the Mongolian Election Law. There are news reports alleging that she accepted a donation from a foreign-invested entity which is prohibited under the Election Law and criminal investigations are being carried out. It is not clear whether she is actually charged for any wrongdoing.

The entity which allegedly provided prohibited donation is Khanbogd Exploration LLC whose sole shareholder is QGX Holdings Limited. Based on the publicly available database of the Legal Entities Registration Office, registration of QGX Holdings Limited (incorporated in the United Kingdom according to the database) as a sole shareholder is updated on 22 August 2024 after the 2024 election although it is not clear whether the identity of the shareholder has changed or not. Based on our search, QGX Holdings Limited appears to have a domicile in Cayman Islands, a British overseas territory. The UK Companies House search does not reveal a company called QGX Holdings Limited. Based on Extractive Industry Transparency Report of 2024, Khanbogd Exploration LLC reported that its parent company is Kerry Group Limited with a domicile in Cook Islands and Cayman Islands.

Based on the above, it appears that QGX Holdings Limited is affiliated with Kerry Group which invested in the Mongolian mining sector since 2008. It is common knowledge that Kerry Group in Hong Kong relates to the Kuok Group controlled by Robert Kuok, a Malaysian billionaire and has vast interests in property and other sectors based in Hong Kong. Kerry Group has close association with MCS Group, a conglomerate with diverse interests in various business sectors and closely cooperated on several joint venture projects over the years, specifically in the mining and hospitality sectors. For example, when Kerry Mining purchased 90% of the issued shares of QGX Limited through its indirectly subsidiary Mongolia Holdings Corporation for the purchase price of US$259 million in 2008, MCS Minerals LLC held 10% interest in the Mongolia Holdings Corporation. MCS Minerals LLC was owned 51% by Odjargal Jambaljamts and 49% by MCS Holding LLC.

Further, Kerry Group invested in Energy Resources LLC, a mining company which holds “Ukhaa Khudag” mining license for a high-quality coking coal project which is part of Tavan Tolgoi, a strategically important deposit. Following the successful initial public offering of shares of Cayman Island-incorporated Mongolian Mining Corporation, a parent company of Energy Resources LLC in October 2011, MCS Group owned 44% of the issued shares of Energy Resources LLC and Kerry Mining held 8.1% of Energy Resources LLC. Mongolian Mining Corporation raised over US$650 million from its initial public offering at the Hong Kong Stock Exchange and spent most of it for the purchase of QGX Coal, which controlled Baruun Naran coking coal project. Kerry Mining made profits of over US$300 million within just 2 years of the takeover of QGX.

According to the Legal Entities Registration database, ultimate beneficial shareholders of Khanbogd Exploration LLC are listed as (1) Kuok Hui Kwong; (2) Kuok Khoon Chen; (3) Kuok Khoon Ean; (4) Kuok Khoon Ho; and (5) Kuok Khoon Hua.

These individuals are all children and descendants of Robert Kuok, the richest man of Malaysia who is dubbed as “Sugar King” and has net worth of over US$ 13 billion. We looked into business interests and associations of these individuals, the scions of the richest person of Malaysia given the ongoing controversies surrounding the illegal campaign donation. Based on our searches, Kuok Hui Kwong is the daughter of Robert Kuok and is currently the chairwoman of Shangri-La Asia Limited, a Hong Kong listed company. Kuok Khoon Chen is the eldest son of Robert Kuok and is the chairman of Kerry Holdings Limited. Kuok Khoon Ean is also Robert Kuok’s son who manages day-to-day operations of the family business. Kuok Khoon Hua is also a son of Robert Kuok and appears to hold various executive positions of Kerry affiliated companies such as Kerry Properties Limited. We were not able to find information on Kuok Khoon Ho.

Based on our searches, it appears that Khangad Exploration LLC is owned by QGX Limited company which was acquired by Kerry Mining in 2008. As the children of Robert Kuok are listed as beneficial owners of QGX Limited, interesting questions arise as to whether the beneficial owners had any knowledge of the political campaign provided to MP Bolormaa Enkhbat in Mongolia in breach of Mongolian law and as to whether the donation was authorized by the beneficial shareholders. If the donation was provided based on proper corporate approvals, questions arise as to why these individuals, who appear to be one of the richest people in Asia, are interested in getting entangled in Mongolian politics and clearly breaching Mongolian laws. Perhaps they could have followed the suit of MCS Group, their business partners in Mongolia who also provided extensive political donation to various political parties and individuals during the general election of 2024. Almost all of the donations were provided through subsidiaries of Mongolian Mining Corporation, in which Kerry Mining still holds 7% interest. More investigations are expected to be carried out in respect of the alleged illegal donation provided by Khangad Exploration LLC and it is to be seen whether Khangad Exploration LLC will be held liable under Mongolian law. It is unclear under Mongolian law, whether beneficial owners of a foreign-invested company would be held liable for providing illegal political donation and whether the children of Robert Kuok would be called into provided testimony or be held liable.

We will report separately on the political donation provided by Mongolian Mining Corporation through its various subsidiaries in Mongolia and whether such donation would also violate Mongolian laws.

By M.Baavar