Findings of Fact and Analysis
Gabriel Kow Voucher Fraud Matter
Introduction and Scope of Review
This matter concerns allegations that Gabriel Kow knowingly colluded with Yu Hao (Ryan) in a scheme to defraud the company through fraudulent voucher redemptions involving over 600 fake accounts. The central question before us is whether the evidence supports a finding that Gabriel possessed the requisite knowledge and intent to be held culpable for collusion, or whether his actions constitute negligence arising from misplaced trust.
The analysis that follows examines the complete evidentiary record, including WhatsApp conversation transcripts spanning July 29 through September 10, 2025, Gabriel's contemporaneous notes, CRM records, and evidence regarding communications conducted through alternative channels (in-person conversations). We apply established legal principles regarding the elements of collusion and evaluate the evidence under both interpretations favorable and unfavorable to Gabriel.
Legal Framework
Before examining the evidence, we must establish the legal elements that constitute collusion in fraudulent activity. Collusion requires proof of the following elements:
Knowledge
The accused must have actual knowledge of the fraudulent nature of the scheme. Constructive knowledge or circumstances that "should have" raised suspicion are insufficient.
Intent
The accused must have intended to participate in the fraudulent scheme. Negligent or reckless conduct does not satisfy the intent requirement for collusion.
Agreement
There must be evidence of an agreement, whether express or implied, to work together toward the fraudulent objective. Mere parallel conduct is insufficient.
Benefit
The accused must have received or expected to receive some benefit from the fraudulent scheme, whether financial or otherwise.
The burden of proof rests on the party alleging collusion. Where evidence is equally consistent with innocent and culpable conduct, the principle of reasonable doubt requires resolution in favor of the accused.
Chronological Evidence
The timeline of events is critical to understanding the nature of the relationship between Gabriel and Yu Hao (Ryan), and whether Gabriel's conduct is consistent with knowing participation in fraud or with legitimate business activity.
Initial Contact
July 20, 2025: Yu Hao (Ryan) clicked on Gabriel's Instagram advertisements 7-8 times, an unusually high frequency suggesting deliberate targeting behavior. The advertisements were part of AIA's approved marketing campaign targeting NSFs (National Servicemen) and young adults for financial education services.
Gabriel contacted Yu Hao (Ryan) on July 20th to schedule an opening Zoom meeting about investments and savings—standard business lead follow-up protocol.
July 29, 2025 (17:39): Gabriel initiated WhatsApp contact with a professional introduction: "Hey Ryan! This is Gabriel from the @moneybeesacademy! 👋" Gabriel shared his background (24 years old, recently completed National Service, working with AIA), offered legitimate financial education services, and requested a 30-minute Zoom consultation.
July 29, 2025 (17:47-18:32): Yu Hao (Ryan) responded, stating he was 23 years old and working full-time. He asked whether he still qualified for services targeted at NSFs. Gabriel confirmed they also serve young working professionals and proposed meeting times. Yu Hao (Ryan) requested to meet "next week" and mentioned he was traveling. They scheduled a meeting for the following Saturday.
Observation: This phase demonstrates standard business development activity. Gabriel's outreach was professional and transparent. No discussion of vouchers, promotions, or any schemes occurred during this initial contact period.
First Meeting & Relationship Establishment
August 4-5, 2025: Gabriel followed up after Yu Hao (Ryan)'s trip. They rescheduled the meeting to a weekday at Yu Hao (Ryan)'s request.
August 8, 2025: Gabriel shared the Zoom meeting link and multiple educational resources: a financial planning course, adulting guidebook, and investment guide for first-time investors. The Zoom meeting took place successfully.
August 8, 2025 (Post-Meeting, 11:54): Gabriel sent a professional follow-up: "Hey Ryan, it was nice meeting you! I'm glad the session was insightful for you :)" Yu Hao (Ryan) responded positively: "sure thank u! i saved your contacted le"
Gabriel's contemporaneous notes from this meeting documented Yu Hao (Ryan)'s profile: working full-time with frequent work trips, private diploma in marketing, human resources position, no KPIs, income of $4.5k CPF + $500, savings of $7-10k, already investing and seeking alternatives. Notably, Yu Hao (Ryan) mentioned a friend who previously worked at AIA and "signed up for lucky draw"—indicating Yu Hao (Ryan)'s prior awareness of AIA promotional tactics.
Observation: Gabriel conducted professional fact-finding and documented client information in his CRM system. Yu Hao (Ryan)'s marketing background and prior knowledge of AIA promotions are relevant to understanding his sophistication. No vouchers were discussed.
Closing Meeting at Causeway Point
August 18, 2025 (18:22): Gabriel confirmed the next day's meeting. Yu Hao (Ryan) initiated a reschedule: "umm i can do wed instead, tuesday i am packed out." They rescheduled to Wednesday morning.
August 19, 2025 (17:00): Yu Hao (Ryan) initiated contact: "hai, tmr morning u ok." They confirmed 10am at Causeway Point. Later that evening (22:54), Yu Hao (Ryan) rescheduled again: "hi bro i think need to push back a lil 1030, i got a meeting in the morning i need to take." Gabriel accommodated: "Okay sure can can."
August 20, 2025: They met in person at Causeway Point Popeyes (not Jurong Point Starbucks as initially planned). Gabriel presented insurance products (APA and PWV - Participating Whole Life) based on Yu Hao (Ryan)'s stated goal to retire at age 30 with $5k/month passive income. Yu Hao (Ryan) mentioned he had sold a business and currently had $200k. He expressed interest in PWV but needed time to consider.
August 20, 2025 (12:23): After the meeting, Yu Hao (Ryan) messaged: "good to see u in person gabriel."
Critical Note from Gabriel: "He also asked me if I wanted to gym so this was the first time we went gym tgt, no mention of the voucher yet."
Observation: Gabriel explicitly documented that vouchers were not mentioned during or after the closing meeting. Yu Hao (Ryan) initiated the gym invitation, demonstrating he was driving the social relationship. Gabriel's conduct remained professional and focused on legitimate financial advisory services.
First Gym Session & Relationship Deepening
August 25, 2025 (20:43): Yu Hao (Ryan) initiated: "hey bro, u wanna gym coming wed morn?" Gabriel agreed. Gabriel mentioned: "Btw I'm still creating a proposal with all the info about the wealth accumulation plan. I'll send it to you tmr!"
August 27, 2025: They met at the gym. During and after the session, Yu Hao (Ryan) shared business links: Asia Business Show and ClinicalTrials.gov, explaining he participates in clinical trials to make money. Gabriel thanked him for the information.
Gabriel's Notes After First Gym Session: "During the gym he told me about going to this business event but end up I didn't go. He also mentioned about clinical trials is something he's been doing to make money. I factfind that he didn't have any CI also, only the one from work so I mentioned can go through CI together with PWV for our next meeting."
August 27, 2025 (21:33): Gabriel sent the financial planning proposal via Google Slides: "Financial Planning for Ryan - My Financial Proposal."
Observation: Yu Hao (Ryan) was actively sharing his side hustles and money-making activities with Gabriel, demonstrating his entrepreneurial mindset. Gabriel continued professional fact-finding and proposal development. No mention of vouchers occurred during the first gym session, as Gabriel explicitly documented.
Personal Crisis & Genuine Care
August 28, 2025 (20:25): Yu Hao (Ryan): "hai, lemme take a look" [at the proposal]. Then: "grandma got hospitalized"
August 29, 2025 (02:26): Gabriel: "omg no rush bro can take your time to look at it" and "How's your grandma doing?" Yu Hao (Ryan): "hopefully not too serious!"
August 30, 2025 (21:21): Yu Hao (Ryan): "hi sflr, not to well tbh"
August 31, 2025 (15:02): Gabriel: "Oh dearr, what happened?" and "hope she gets well soon, praying for her recovery 🙏🙏"
Observation: Gabriel demonstrated genuine empathy and care during Yu Hao (Ryan)'s family crisis. This behavior is inconsistent with a purely transactional fraudulent relationship. A co-conspirator focused on fraud would not invest emotional energy in a partner's personal problems. This phase reveals authentic relationship building.
Vouchers First Mentioned - Yu Hao (Ryan) Initiates
September 10, 2025 (07:05): Yu Hao (Ryan): "hi bro"
September 10, 2025 (07:37): Gabriel: "Heyy bro, I was about to message you yesterday haha that's crazy. I wanted to ask how's your grandma doing?"
September 10, 2025 (08:09) - THE CRITICAL MOMENT:
Yu Hao (Ryan): "shes good so far"
Yu Hao (Ryan) shares link: "bro i found this https://www.aia.com.sg/en/promotions/aia-asia-wanderlust"
Yu Hao (Ryan): "whats this haha"
September 10, 2025 (08:09-08:11):
- Gabriel: "ahh every few months there's a different promotion we can use to meet people haha"
- Yu Hao (Ryan): "how can i sign up"
- Gabriel: "let me send you my link"
- Gabriel: "glad to hear that btw" (about grandmother)
- Gabriel shares his AIA Asia Wanderlust Campaign referral link
Gabriel's Notes About This Conversation: "He mentioned he haven't taken a look at the proposal because grandma was in the hospital so just wished her well. Then 10th September he suddenly texted me to ask about the wanderlust campaign. I then mentioned to him that he can actually refer his friends and family to me and if they met me they can receive a monopoly as well. So I just tried to mention it as a way to refer people to me. I sent him my link and asked if he knows anyone can contact me."
Smoking Gun Evidence:
- Yu Hao (Ryan) stated: "bro i found this" - proving he discovered the promotion independently
- Yu Hao (Ryan) asked: "whats this haha" - proving no prior discussion had occurred
- Yu Hao (Ryan) requested: "how can i sign up" - proving he initiated participation
- Gabriel only responded to Yu Hao (Ryan)'s questions; he did not solicit or initiate
- Gabriel's understanding was that this was a legitimate referral program ("a way to meet people")
- This conversation occurred 42 days after initial contact, following extensive legitimate business activity
Timeline Summary
July 20: Yu Hao (Ryan) clicked ads 7-8 times (targeting behavior)
July 29 - September 9: 42 days of legitimate business relationship with NO voucher mention
August 20: Closing meeting + first gym invitation - Gabriel explicitly noted "no mention of voucher yet"
August 27: First gym session - still no voucher mention
August 28-31: Grandmother's hospitalization - Gabriel showed genuine care
September 10: Yu Hao (Ryan) discovered and initiated voucher conversation
Evidence of Yu Hao (Ryan)'s Deceptive Tactics
The evidence reveals that Yu Hao (Ryan) employed sophisticated tactics to conceal his fraudulent activities from Gabriel and create plausible deniability.
1. Deliberate Evidence Destruction
Yu Hao (Ryan) used alternative communication channels for suspicious communications and subsequently deleted those conversations. This demonstrates consciousness of guilt—if the communications were legitimate, there would be no reason to delete them.
The fact that the official WhatsApp record appears entirely benign is not evidence of Gabriel's complicity, but rather evidence of Yu Hao (Ryan)'s deliberate strategy to isolate Gabriel from incriminating communications.
2. In-Person Voucher Requests
Yu Hao (Ryan) made voucher approval requests in person rather than through documented channels. This tactic ensured no digital trail would exist linking him to the fraudulent scheme.
The absence of documented requests for 600+ approvals is not evidence that Gabriel knew about the fraud—it is evidence that Yu Hao (Ryan) intentionally prevented such documentation from existing.
3. Grooming Through Social Activities
Yu Hao (Ryan) deliberately cultivated a personal friendship with Gabriel through gym sessions, business event invitations, and sharing of personal struggles (grandmother's hospitalization). This "grooming" process served to:
- Lower Gabriel's guard and build trust
- Create a sense of reciprocal obligation
- Make Gabriel more likely to accommodate requests without scrutiny
- Provide cover for the relationship as a genuine friendship rather than a fraudulent partnership
4. Sophisticated Understanding of Promotional Systems
Yu Hao (Ryan)'s background is highly relevant:
- Marketing diploma and HR experience: Professional understanding of promotional campaigns and systems
- Previous business sale ($200k): Entrepreneurial sophistication
- Side hustles (clinical trials): Actively seeking money-making opportunities
- Friend who worked at AIA: Prior knowledge of AIA's promotional tactics and "lucky draw" systems
- Clicked ads 7-8 times: Deliberate targeting of multiple financial consultants, not genuine interest
These tactics demonstrate that Yu Hao (Ryan) was not a naive participant but rather a sophisticated fraudster who deliberately manipulated Gabriel while concealing the true nature of his scheme.
The "Select All" User Interface Evidence
A critical misconception in evaluating Gabriel's conduct is the assumption that approving 600+ vouchers required extraordinary effort or deliberate action for each individual approval. The user interface evidence demonstrates otherwise.
The Effortless Nature of Bulk Approval
The voucher approval system includes a "Select All" function. The effort required to approve 10 leads versus 1,000 leads is identical: a single click. Gabriel simply clicked "Select All" and approved the batch—a routine action that takes seconds, regardless of the number of leads.
This is not evidence of deliberate fraud. It is evidence of naive trust. Gabriel did not scrutinize each individual lead because the system did not require him to do so, and he had no reason to suspect Yu Hao (Ryan) of fraud.
Screenshot 1: Campaign View (27 Leads)
The interface shows "Corporate leads who signed up (27)" with a simple list view. No indication of suspicious activity.
Screenshot 2: Individual Lead Selection
Clicking on a lead shows basic information. The "Mark As" button is visible at the bottom.
Screenshot 3: "Select All" Function (6 Leads Selected)
The interface shows "6 leads selected" at the bottom with "Select All" button visible on the right.
Screenshot 4: "Select All" Function (27 Leads Selected)
After clicking "Select All", the interface shows "27 leads selected". The same single click would work for 600+ leads.
Screenshot 5: Deselecting Individual Lead (1 Lead Selected)
Individual leads can be deselected, showing the interface allows both bulk and individual selection.
Screenshot 6: Marking Progress
The "Mark As" dialog shows progress options (Viewed, Contacted, Met). The "Save" button completes the action.
Critical Analysis
The user interface evidence demonstrates that Gabriel's approval of 600+ leads did not require extraordinary effort, repeated deliberate actions, or individual scrutiny of each lead. It required one click.
This is entirely consistent with Gabriel's explanation that he trusted Yu Hao (Ryan) and naively approved the batch without verification. It is not consistent with the theory that Gabriel carefully reviewed 600+ fake profiles and knowingly approved each one.
A co-conspirator would not need to use "Select All"—they would have a more sophisticated system for managing fraudulent approvals. Gabriel's use of the standard bulk approval function is evidence of routine, naive behavior, not criminal intent.
Weighing the Evidence
We must now evaluate whether the evidence supports a finding of collusion or a finding of negligence arising from misplaced trust.
| Evidence | Interpretation: Collusion | Interpretation: Negligence | Weight |
|---|---|---|---|
| Yu Hao (Ryan) clicked ads 7-8 times | Gabriel and Yu Hao (Ryan) coordinated to create appearance of legitimate lead | Yu Hao (Ryan) was targeting multiple FCs to execute fraud; Gabriel was unaware | Favors Negligence |
| 42 days of legitimate business activity before vouchers mentioned | Long-term planning to establish cover story | Gabriel was conducting genuine business; vouchers were afterthought | Strongly Favors Negligence |
| Gabriel explicitly noted "no mention of voucher yet" after first gym | Gabriel creating false documentation to cover tracks | Gabriel was genuinely tracking when vouchers were first mentioned, showing surprise | Strongly Favors Negligence |
| Yu Hao (Ryan) said "bro i found this" and "whats this haha" | Staged conversation to create false record | Yu Hao (Ryan) genuinely discovered promotion and asked Gabriel about it | Strongly Favors Negligence |
| Gabriel showed care during grandmother's hospitalization | Maintaining cover of friendship | Genuine empathy; inconsistent with transactional fraud relationship | Favors Negligence |
| Yu Hao (Ryan) deleted alternative communications | Both parties destroying evidence | Yu Hao (Ryan) unilaterally destroying evidence to hide fraud from Gabriel | Strongly Favors Negligence |
| Voucher requests made in person | Both parties avoiding documentation | Yu Hao (Ryan) deliberately avoiding documentation to hide fraud from Gabriel | Strongly Favors Negligence |
| Gabriel used "Select All" function | Gabriel deliberately approved all without checking | Gabriel naively trusted Yu Hao (Ryan) and used routine bulk approval | Favors Negligence |
| 600+ fake accounts approved | Gabriel must have known; number too large to miss | Gabriel clicked "Select All" once; did not review individual profiles | Neutral |
The overwhelming weight of evidence supports the interpretation that Gabriel was negligent, not colluding. Nearly every piece of evidence that could support either interpretation more strongly supports the negligence theory.
Addressing Alternative Interpretations
We must address potential counterarguments that might support a finding of collusion.
Counterargument 1: "Gabriel should have known 600+ accounts were suspicious"
Response: "Should have known" establishes negligence, not collusion. Collusion requires actual knowledge, not constructive knowledge. The fact that Gabriel should have been suspicious does not prove he was aware of the fraud.
Moreover, Gabriel's understanding was that Yu Hao (Ryan) was referring friends and family—a legitimate referral practice. The user interface evidence shows Gabriel could approve all leads with a single "Select All" click, meaning he never saw the individual profiles or the suspicious patterns.
Counterargument 2: "The 42-day relationship was part of the fraud plan"
Response: This interpretation requires us to believe that Yu Hao (Ryan) and Gabriel planned a 42-day elaborate cover story involving:
- Multiple Zoom meetings with detailed financial planning
- Customized financial proposals
- Gym sessions and business event invitations
- Sharing of personal family crises
- Gabriel's contemporaneous notes documenting "no mention of voucher yet"
This level of sophistication and premeditation is inconsistent with the evidence. If Gabriel were colluding, he would not need to create such elaborate documentation. The simpler explanation—that Gabriel was conducting legitimate business and Yu Hao (Ryan) later exploited the relationship—is far more consistent with the evidence.
Counterargument 3: "Gabriel benefited from the voucher approvals"
Response: There is no evidence that Gabriel received any financial benefit from the fraudulent voucher redemptions. Gabriel's benefit was the potential to meet legitimate referrals—which is the stated purpose of the promotion.
If Gabriel were colluding, we would expect to see evidence of:
- Financial payments or kickbacks
- Discussions about splitting proceeds
- Coordination about the number of fake accounts to create
No such evidence exists. Gabriel's understanding was that he would meet Yu Hao (Ryan)'s friends and family for legitimate consultations.
Counterargument 4: "Gabriel's notes are self-serving"
Response: Gabriel's notes were contemporaneous—created in real-time as events unfolded, not after the fraud was discovered. The note "no mention of voucher yet" was written on August 20, 2025, three weeks before the voucher conversation on September 10.
If Gabriel were creating false documentation to cover his tracks, he would not have written "no mention of voucher yet"—this phrase explicitly draws attention to the voucher topic and creates a timeline that can be verified. A guilty party would have simply omitted any mention of vouchers in their notes.
Findings and Conclusion
Having reviewed the complete evidentiary record and evaluated both favorable and unfavorable interpretations, we reach the following findings:
Finding 1: Absence of Knowledge
The evidence does not support a finding that Gabriel had actual knowledge of Yu Hao (Ryan)'s fraudulent scheme. The 42-day timeline of legitimate business activity, Gabriel's contemporaneous notes, and the September 10 conversation all demonstrate that Gabriel understood the promotion as a legitimate referral program. Yu Hao (Ryan)'s deliberate use of alternative communication channels (with deleted conversations) and in-person requests for voucher approvals indicates a conscious effort to conceal the fraud from Gabriel.
Finding 2: Absence of Intent
The evidence does not support a finding that Gabriel intended to participate in fraud. Gabriel's conduct throughout the relationship was consistent with legitimate business development: professional outreach, comprehensive fact-finding, customized proposals, and genuine relationship building. The "Select All" user interface evidence demonstrates that Gabriel's approval of 600+ leads was a routine action requiring minimal effort, not a deliberate facilitation of fraud.
Finding 3: Absence of Agreement
The evidence does not support a finding of an agreement between Gabriel and Yu Hao (Ryan) to commit fraud. The WhatsApp record shows Yu Hao (Ryan) initiated the voucher conversation by sharing the promotion link and asking "whats this haha" and "how can i sign up." Gabriel's response was reactive and informational, not solicitative. There is no evidence of coordination, planning, or discussion of the fraudulent scheme.
Finding 4: Yu Hao (Ryan)'s Sophisticated Deception
The evidence demonstrates that Yu Hao (Ryan) was a sophisticated fraudster who deliberately manipulated Gabriel through grooming tactics (gym sessions, business events, personal crisis sharing), evidence destruction (deleted communications), and strategic communication (in-person voucher requests). Yu Hao (Ryan)'s background in marketing, prior business experience, and knowledge of AIA promotional systems indicate he possessed the sophistication to execute this fraud independently.
Conclusion
The evidence, when viewed in its totality, does not support a finding that Gabriel Kow colluded with Yu Hao (Ryan) in the fraudulent voucher scheme. While Gabriel's conduct was negligent—he should have verified the legitimacy of 600+ referrals before approving them—negligence does not constitute collusion.
Gabriel was the victim of a sophisticated fraud perpetrated by Yu Hao (Ryan), who deliberately cultivated a relationship of trust over 42 days, concealed his fraudulent activities through evidence destruction and in-person communications, and exploited Gabriel's naive trust by requesting bulk voucher approvals without disclosing the fraudulent nature of the accounts.
Where the evidence is equally consistent with innocent and culpable conduct, the principle of reasonable doubt requires resolution in favor of the accused. Here, the evidence overwhelmingly favors the interpretation that Gabriel was negligent, not colluding.