Investigation Report on the Bill Guan Case
Executive Summary:
This report, based on internal Chinese Communist Party documents, congressional materials, international human rights investigation reports, and public records, assesses that the Chinese Communist Party (CCP) has long carried out a premeditated, organized, and transnationally conducted systematic suppression campaign against the Falun Gong religious group and overseas media groups founded by some Falun Gong practitioners such as the Epoch Times. This suppression model employs a comprehensive strategy integrating information warfare through public opinion, cyber and personal attacks, legal warfare, economic coercion, and overseas agent networks. Its nature constitutes state-sponsored transnational suppression. In this context, the case of the Epoch Times CFO Bill Guan[1]raises serious questions: could U.S. judicial procedures be exploited by external forces to serve the suppression objectives of foreign regimes, thereby threatening U.S. sovereignty, national security, and judicial independence?
Part One: Analysis of the Indictment Against Bill Guan by the SDNY —Clear Legal Defects, Insufficient Evidence, and Fundamental Flaws
This section analyzes the SDNY indictment against Weidong Guan (a/k/a Bill Guan). Based on 18 U.S.C. §§ 1956–1957, public financial records, and industry compliance standards, the indictment has serious defects in factual basis, evidence, and legal elements. It relies excessively on vague, conjectural assertions rather than concrete, traceable proof, casting significant doubt on the validity of the charges.
This analysis is based solely on the publicly available text of the indictment (Case No. 24 CRIM 322, U.S. District Court, Southern District of New York). It includes no confidential, internal, non-public, or investigative materials. All paragraph citations (¶) are quoted directly from the indictment. This document provides an objective analysis only of the legal framework and factual allegations stated in the indictment. It does not constitute legal advice, represent any party's position, or imply any finding of fact or determination of guilt.
I. No Established Predicate Offense: The Indictment Fails to Identify Any Specified Unlawful Activity (SUA)
1. Money laundering is not a standalone criminal offense
Under federal law, the money laundering statutes (18 U.S.C. §§ 1956 and 1957) do not criminalize financial activity standing alone. Conviction requires proof of:
- a clearly defined predicate offense constituting a Specified Unlawful Activity (SUA);
- funds that are proceeds of that offense;
- knowledge and intent by the defendant regarding the illicit origin of those funds.
2. The indictment fails to establish any SUA
The SDNY indictment fails to do the following:
• identify a specific fraud scheme;
• name any identifiable victims;
• describe the mechanics or execution of any alleged fraud;
• charge wire fraud, bank fraud, identity theft, or any other offense as a predicate SUA; or
• present transactional, documentary, or forensic evidence linking the charged funds to criminal activity.
Instead, the indictment vaguely alleges the existence of $67 million in “illegally obtained funds,”( ¶1) “crime proceeds,” (¶2) or “various frauds.” (¶8) Such labels carry legal significance only when anchored to specific, pleaded facts. In the absence of a defined and supported SUA, the money laundering counts fail as a matter of law.
II. Failure to Plead a Predicate SUA Through Deliberate Buyer–Seller Vagueness
The indictment, when alleging money laundering by the Make Money Online team (MMO Team), focuses entirely on the “purchase” and “transfer” stages, yet never explicitly charges any concrete upstream offense (i.e., any Specified Unlawful Activity, or SUA). This renders the whole accusatory chain fundamentally incomplete and legally deficient. Specifically:
1.The indictment repeatedly states that MMO Team used cryptocurrency to “purchase” prepaid debit cards and gift cards on the platform, clearly characterizing MMO Team as a buyer.
2.The indictment directly states that “members of the MMO Team and others used cryptocurrency to knowingly purchase tens of millions of dollars in crime proceeds.” (¶2) This constitutes an admission that the funds on these prepaid cards were derived from criminal activity.
3.The indictment explicitly states: “These prepaid debit cards were issued by different debit card companies and loaded with U.S. dollars that had been unlawfully obtained through various frauds (i.e., the crime proceeds).” “The crime proceeds were sold on Cryptocurrency Platform I to affiliates of the Media Company’s Foreign Office at discounted rates of approximately 70 to 80 cents per dollar and in exchange for cryptocurrency.” (¶8)
This clearly indicates that the sellers were precisely the individuals who obtained the funds through typical predicate offenses such as “stolen identification information) and “fraudulently procured unemployment insurance benefits” (see ¶3, ¶8). However, the indictment describes the MMO Team as “purchased these crime proceeds at a discount and then transferred those proceeds into bank accounts held by the Media Entities” (¶2), placing the entire focus on the downstream buyers and the subsequent fund transfers, while making virtually no specific allegations against the upstream sellers—that is, the true originators and perpetrators of the fraud.
On anonymous cryptocurrency trading platforms, buyers typically find it difficult to fully verify the seller's true identity, the source of funds, or the legitimate origin of prepaid debit or gift cards— unless there is direct evidence proving that the buyer "knew" these cards had been loaded with criminal proceeds. If law enforcement agencies assumed that all such funds from "discounted transactions" are criminal proceeds solely based on the discount, then why have a large number of similar platforms and discounted trading activities not yet been systematically shut down or comprehensively intervened in by the Financial Crimes Enforcement Network (FinCEN), the U.S. Securities and Exchange Commission (SEC), or the U.S. Department of Justice (DOJ)? This indicates that, in the absence of direct evidence linking upstream crimes and proof of the buyer's subjective "knowledge," the mere act of purchasing at a discount does not necessarily satisfy the elements required for a money laundering offense. Instead, it is more likely to constitute normal secondary-market circulation. If the upstream fraudsters are the true source of the illegal funds, why not prioritize cracking down on fraudulent organizations and sellers, rather than designating the downstream buyers—i.e., the MMO team—as the principal offenders? This inevitably raises a reasonable question: Does law enforcement in this case exhibit selective bias, targeting only the financial executive of a specific anti-Communist media outlet while failing to apply the same level of scrutiny to the vast number of similar anonymous transactions in the market?
III. The “MMO Team” Narrative: A Constructed Organizational Fiction
The indictment portrays the “MMO team” as an entity “located in a particular foreign office of the Media Company … under GUAN’s management” (¶2). Yet it offers zero evidence that any such formal overseas office ever existed—no corporate registration, no employee list, no budget records, no office lease, nothing. The term more closely resembles an informal catch-all for scattered online supporters or donors than a structured, hierarchical criminal organization. If the MMO “team” has no demonstrated corporate reality, then the allegations that Guan “managed” it and conspired with it (¶14) collapse at their foundation.
Why does the indictment get to brand Guan as the ringleader using an utterly unverified “team” label? If the MMO Team is essentially a constructed fiction, why not target the upstream fraud perpetrators who actually stole the identities and laundered the original proceeds? And if these were just ordinary online fundraising activities, on what basis is this being charged as a sprawling transnational money-laundering conspiracy?
IV. Revenue Growth in 2020: Criminalization of Lawful Business Success
The indictment relies on a claimed “increased annual revenue over the previous year of approximately 410 percent—from approximately $15 million to approximately $62 million” (¶4)in the Media Company’s 2020 revenue (as reflected in its “internal financial accounting”) as circumstantial evidence of illicit funding inflows and money laundering. However, this allegation fails both as a matter of law and fact. The information in the table below is derived from publicly available financial data (IRS Form 990 filings): [2]
|
Year |
Total Revenue |
Subscriptions Revenue (Print &Digital) |
Contributions |
Subscriptions Revenue/ Total Revenue % |
Contributions / Total Revenue |
|
2019 |
15,478,665 |
10,681,874 |
835,208 |
69.01% |
5.40% |
|
2020 |
70,590,023 |
62,191,952 |
5,028,748 |
88.10% |
7.12% |
|
2021 |
121,545,102 |
115,257,305 |
3,054,026 |
94.83% |
2.51% |
|
2022 |
127,999,557 |
121,728,113 |
3,384,709 |
95.10% |
2.64% |
|
2023 |
122,102,193 |
111,775,558 |
2,193,027 |
91.54% |
1.79% |
|
2024 |
125,770,097 |
116,210,299 |
1,758,497 |
92.39% |
1.40% |
Note: According to the review of Form 990 filings, 'Subscription' revenue typically refers to print (hard-copy) subscriptions, whereas 'Web and Media Income' refers to digital/online subscriptions revenue.
1.The actual percentage of growth from 2019 to 2020 was approximately 356% (rather than the 410% state in the indictment), demonstrating that the indictment’s figure is mathematically inaccurate.
2.The growth primarily came from subscription revenue (representing approximately 93.47% of the total year-over-year increase in 2020), while donations represented a minimal share and have continued to decline since 2021.
- Total Revenue Increase (2020 - 2019): 70,590,023 - 15,478,665 = 55,111,358
- Subscription revenue increase (2020 - 2019): 62,191,952 - 10,681,874 = 51,510,078
- Proportion: 51,510,078 / 55,111,358 ≈ 0.9347 (i.e., 93.47%)
- Total revenue has stabilized between $122 million and $126 million since 2020, driven entirely by subscriptions rather than being driven by “the unlawful proceeds of the Money Laundering Scheme” as alleged in ¶5.
If the DOJ enforces the law impartially, why does it refuse to acknowledge the fact of a subscription explosion, instead treating the normal phenomenon of legitimate growth as evidence of money laundering? If the income growth is attributed to business success, it inevitably raises questions about whether the justice system is being used to target specific media outlets.
V. Serious Drafting and Procedural Irregularities
The indictment cites 18 U.S.C. § 1947(f)(1), a provision that does not exist in the United States Code. The correct statutory reference is 18 U.S.C. § 1957(f)(1). In the context of a federal felony indictment, such an error is not de minimis. It raises substantial concerns regarding:
• the adequacy of legal review and supervisory oversight;
• potential reliance on recycled or boilerplate charging templates;
• compliance with constitutional notice requirements; and
• the overall reliability and precision of the charging instrument.
Conclusion
This analysis of several key issues concludes that the indictment relies excessively on inferential language, generalized descriptions, and indirect associations, failing to provide specific, verifiable facts and an evidentiary chain sufficient to establish the core elements of money laundering (predicate SUA, knowledge of illegality, and illicit source of funds). It alleges a $67 million” illegally obtained funds”, “Money Laundering Scheme” (¶1), yet identifies no specific predicate offense, victims, fraud mechanism, or direct trace of the funds—relying instead on vague references to “various frauds” (¶8), Absent a clear allegation of upstream crimes, proof of an organized entity, and a reasonable account of legitimate revenue growth, the charges rest on a weak and fundamentally flawed legal foundation. These shortcomings make the indictment difficult to sustain on publicly available materials alone and raise reasonable questions about case motives, selective enforcement, and procedural rigor.
This conclusion is strictly limited to an analysis of the publicly available text of the indictment, does not consider any undisclosed investigative materials, trial evidence, or final judicial determinations, and should not be construed as any finding of fact or culpability.
Part Two: The background of the Bill Guan case points to the Chinese Communist Party
I. Whistleblower testimony indicates a connection between the Bill Guan case and the CCP’s overseas operational deployments.
|
Source |
Event Date |
Main Content (related to the Epoch Times and NTDTV) |
|
Australian-based legal scholar Yuan Hongbing revealed to the Epoch Times on December 2024 |
Oct. 2022 |
Xi Jinping chaired a secret high-level meeting to launch a new international strategy. The Central Political and Legal Affairs Commission will coordinate with the United Front Work Department and the Ministry of Foreign Affairs to support Chen Yixin’s Ministry of State Security in its anti-Falun Gong overseas and international operations. The Ministry of State Security will lead in key overseas regions and establish anti-Falun Gong workstations, directly targeting the founder through character assassination. Priority focus: strike the Epoch Times and NTD in the United States—the CCP’s main 'hostile forces'—via media warfare and legal warfare, mainly using unofficial media and self-media for covert attacks. Infiltrate media and employ 'advanced black' tactics to destroy their credibility.[3] |
|
Falun Dafa Information Center (MPS Provincial-level Conference Minutes) |
June 2024 |
“The meeting requires all provincial-level governments to provide resources to fully support [names of social media influencers targeting Falun Gong and Shen Yun], etc. to fight with Falun Gong… Supply all malicious information on Falun Gong gathered by the Public Security internally.” “Mobilize concealed agents to create and escalate the internal conflicts of Falun Gong, to expand nonstop the fighting strength, depth, and reach of [social media influencers targeting Falun Gong and Shen Yun] …they must attract the continuous attention of the entire United States society, and force the U.S. government to strike on all fronts, eliminating the force of Falun Gong.” — Notes from Ministry of Public Security meetings held in June 2024. [4] |
|
Falun Dafa Information Center (CITIC Foundation for Reform and Development Studies report) |
July 2024 |
“Mobilize central state media resources, university think tanks and other resources; take advantage of the U.S. election and the conflicts between the two parties… actively share defamatory information about Falun Gong with overseas media, and provide support… content suitable for short, catchy videos should continue to be disseminated via overseas social media to increase coverage. Suppress Falun Gong’s internet traffic by buying ads [and] SEO optimization.”— Notes on the Chinese state-run CITIC Foundation for Reform and Development Studies’ July 2024 internal report[5] |
|
Huasheng (pseudonym, CCP public security insider revealed to the Epoch Times) |
Nov. 2024 |
“The current plan began in spring 2024, triggered by the new Minister of State Security Chen Yixin.” [6]“Since spring this year, they have been secretly plotting the latest attacks. The goal is to destroy Falun Gong’s overseas forces, dismantle the organization, and fully resolve the Falun Gong issue before year-end.” “Chen Yixin proposed the overseas attack plan due to his close ties to the CCP leader and personal ambition. In practice, it is being executed by Bureau 4 of the Ministry of Public Security, linked to the longstanding ‘610’ operations, and also involves Public Security Minister Wang Xiaohong.”[7] |
|
WOIPFG (Top-secret intelligence) |
Dec. 2024 |
Activate all CCP "special agents" to approach the core members of Trump's team; increase support for individuals opposing Falun Gong by provide more materials and intelligence, including photos and videos and financial assistance; continue to intensify attacks and smear campaigns against Shen Yun, the Epoch Times, and Falun Gong's "key individuals" and "targeted individuals."; attacks and smear campaigns against selected high-ranking individuals within Falun Gong and the Epoch Times; the main goal is to make every effort to sabotage the relationship between Falun Gong and the United States. [8] |
|
WOIPFG (Beijing high-level intelligence) |
Jan. 2025 |
Xi Jinping’s strategic objective is to confront the United States. The CCP treats Falun Gong as inseparable from the U.S., making attacks on its founder, Shen Yun, and the Epoch Times part of a broader anti-U.S. campaign. By fabricating allegations of legal violations, the CCP seeks to pressure the U.S. government to withdraw support and ultimately ban Falun Gong. The Epoch Times’ strong U.S. influence explains why it and its key figures are primary targets, while The New York Times’ attacks align with this broader strategy. These CCP-driven smear campaigns—an element of unrestricted or hybrid warfare—will persist unless the U.S. government intervenes, which is precisely what the CCP fears.[9] |
|
Shen Liang (Pseudonym, CCP public security insider) |
January 2025 |
“The CCP’s sudden large-scale overseas attack on Falun Gong isn’t just about targeting Shen Yun or Falun Gong—their real conspiracy is much bigger.” “Chen Yixin has stated that if Falun Gong isn’t eliminated, and the U.S. joins forces with Falun Gong to formally investigate the persecution inside China—including live organ harvesting—the CCP’s crimes would be exposed internationally. This could lead to the collapse of the Party and country, and even send top leaders, including Xi Jinping, to international tribunals.” “Their strategy is to sue Falun Gong practitioners in the U.S.—starting with individuals, then groups, and finally the whole organization. If even one case succeeds, it will trigger more accusations, ultimately destroying Falun Gong. Once the U.S. government discredits Falun Gong, the crimes committed by the CCP in China will no longer face scrutiny, international attention, or prosecution.”[10] |
The main features are summarized as follows:
|
Dimension |
Specific Content |
Motivation/Impact |
|
Highest-level direct involvement
|
The top leadership directs a highly organized and strategic system of transnational repression: Xi Jinping chaired secret meetings; Minister of State Security Chen Yixin advanced overseas implementation; Minister of Public Security Wang Xiaohong coordinated operations. |
Personal ambition + preventing international accountability for organ harvesting from Falun Gong practitioners + guarding against risks of "international tribunal trials" and "party/state collapse." |
|
Cross-departmental coordination
|
Involves multiple departments including the Political and Legal Affairs Commission, State Security, Public Security, United Front, Foreign Affairs, CITIC Foundation, etc. Employs "red capital" funding, AI + hacker surveillance, agent/informant infiltration. |
Mobilization of state power with highly integrated resources, forming a complete “state–periphery–proxy” network of unrestricted warfare. |
|
Multi-front transnational operations |
Media warfare: Funding influencers, fake accounts for dissemination, smear short videos, leveraging mainstream and social media to stigmatize. Legal warfare: Multiple lawsuits filed in the U.S. to create public opinion-based convictions. Intelligence warfare: Activating agents for infiltration and creating internal divisions. Digital warfare: SEO suppression of traffic, search engine manipulation. Repression integrates AI and big data monitoring. |
Adoption of “innovative” hybrid warfare methods under a legal façade; highly covert and difficult to detect. Seeks to undermine credibility, cut off support, draw social attention. Turns the CCP's transnational repression into an internal U.S. struggle.
|
|
Consistent focus on targets
|
Epoch Times/New Tang Dynasty (key figures), Shen Yun, Falun Gong founder (character assassination).
|
Destroys the U.S. government's relationship with Falun Gong and forces the U.S. government to eradicate Falun Gong. |
|
Timeline |
Escalation of transnational repression began in 2022 following Xi’s secret meeting that deployed a new strategic direction; intensified in spring 2024 during the election year, with the stated goal of eliminating Falun Gong from the United States by year’s end. |
Long-term and continuous. Deeply linked to U.S. elections and politics; exploits bipartisan divisions and amplifies political conflict. |
|
Main battlefield
|
The United States as the main arena, with global expansion. Falun Gong and the United States are viewed as “one entity”; attacking the founder of Falun Gong, Shen Yun, and the Epoch Times is seen as part of the CCP’s broader strategy of confronting the United States. |
Divides and disintegrates the U.S. from within, a reverse attack on democratic institutions, challenging the foundational principles of the U.S. and threatening sovereign security. |
|
Intelligence sources
|
Multi-source intelligence cross-verification with high consistency, forming an indirect but comprehensive evidentiary chain that excludes coincidence. |
Highlights Xi Jinping’s strategic objectives toward the United States and reinforces the assessment that these are not isolated incidents. |
The following are just a few examples to further verify the authenticity and credibility of the internal intelligence.
Example One: Utilizing Mainstream Media
From August 2024 to 2025, the New York Times published more than a dozen articles attacking Falun Gong, Shen Yun Performing Arts, and the Epoch Times. In terms of both the timing and frequency of publication, as well as the narrative framing, these articles corresponded closely with—and were highly aligned with—the Chinese Communist Party’s escalated plans for transnational repression against Falun Gong. Multiple sources have indicated connections between The New York Times and the CCP (a few examples are provided below):
1.Over the past 25 years, The New York Times has frequently exhibited bias in its reporting on China, disregarding the fact that the Chinese Communist Party (CCP) has carried out brutal persecution and atrocities against Falun Gong practitioners.[11] This is especially true regarding the crime of live organ harvesting from Falun Gong practitioners by the CCP.[12]
2.The reporter for the articles is Nicole Hong (Chinese name: 洪芊芊 Hong Qianqian). Her father, George Hong (Chinese name: 洪朝辉 Hong Chaohui),[13] is an overseas "honorary council member" [14] of the Western Returned Scholars Association,[15] a direct organization under the United Front Work Department of the Chinese Communist Party (CCP), which is responsible for overseas infiltration and intelligence gathering. He has twice been received and photographed together with former Chinese President Jiang Zemin at the Great Hall of the People in Beijing, China.[16] At the 100th anniversary celebration of the Western Returned Scholars Association, CCP leader Xi Jinping stated that its “work targets have expanded to the entire globe.”[17]
3.Tucker Carlson stated on Fox News that financial disclosures revealed that The New York Times received over $100,000 per month from China Daily, an official outlet of the Chinese Communist Party, to publish paid propaganda.[18]
4.Several employees of The New York Times previously worked for China Daily, an English-language newspaper controlled by the Chinese Communist Party. In recent years, China Daily has paid tens of millions of dollars to U.S. media outlets to publish Beijing-approved propaganda content.[19]
5.Publicly available information indicates that the current executive editor of The New York Times, Joseph Kahn, has had unusually close and discreet ties to the Chinese Communist regime—particularly to the Shanghai faction associated with Jiang Zemin.[20]
Example Two: Buying Off Well-Known Internet Celebrities / Influencers
YouTuber Tim Pool (a channel with over 4 million subscribers and 3 billion views) publicly stated in October 2024 that he had received an email from someone suspected to be a CCP proxy/agent, offering him $200 to upload an anti-Falun Gong video (a short, 5–10-minute negative clip). He refused, but implied that others might have accepted.[21]
Example Three: X Platform Removes Thousands of Fake Accounts
Multiple media investigations have found that a large number of fake/low-activity accounts have appeared on the X social media platform (most created after April 2024, with zero or very few followers), systematically amplifying anti-Falun Gong and Shen Yun content, particularly boosting negative articles by The New York Times targeting Falun Gong and Shen Yun.[22]
Example Four: Undermining the Relationship Between the U.S. Government and Falun Gong
In September 2025, CCP hackers impersonated the Epoch Times three times, sending bomb threats and violent emails to the White House and several U.S. federal agencies, then forwarded screenshots of the messages to the Epoch Times. [23] Multiple U.S. officials strongly condemned the acts as serious crimes and examples of CCP transnational repression and unrestricted warfare against the United States, calling for legal accountability.[24]
II. Leaked CCP documents show that the initiation of the Bill Guan case may have originated from the CCP's overseas operations deployment.
1. Personnel Appointments, Organizational Structure, and Mission Deployment
According to documents obtained by the World Organization to Investigate the Persecution of Falun Gong (WOIPFG), a joint appointment notice issued by the CCP’s Ministry of Public Security (MPS) and Ministry of State Security (MSS) appointed Wu Xiuhua as Director of the “North America Operations Office” (see screenshot).[25]

Here is the English translation of the document:
Ministry of Public Security of the People's Republic of China, Ministry of State Security of the People's Republic of China
Document jointly issued by the Ministries of Public Security and State Security (2021) Joint Document No. 3-39
Appointment Order Regarding Comrade Wu Xiuhua
It is hereby decided to appoint: Comrade Wu Xiuhua, who originally served as the Director (Division Chief) of the Second Division of the Joint Office for Combating and Handling Falun Gong, to the position of Director of the North America Falun Gong Combat Work Division (at the level of deputy bureau-director / vice-department level), and to relieve him of his previous position as Director of the Second Division of the Joint Office.
Wu Xiuhua, male, Han nationality, born on August 25, 1966, member of the Communist Party of China, university education. He has organized and participated many times in various tasks of combating Falun Gong practitioners, including handling their petitions in Beijing, dissemination activities, practicing sessions, and infiltration operations targeting party and government organs. He possesses rich experience in combating Falun Gong. During the epidemic period in the North America region, Falun Gong activities have become even more rampant. According to the decision of the Party Committee meeting of the Joint Office in March, the North America Falun Gong Combat Work Division, which was originally at the department-director level (正处级), has been upgraded/adjusted to the deputy bureau-director level (副局级) in order to strengthen the intensity of the combat work.
2. Key Findings Reflected in the Appointment Document
- The document indicates that the CCP’s Ministry of Public Security and the Ministry of State Security jointly operate a cross-ministry entity, commonly referred to as the "Joint Office for Cracking Down on Falun Gong."
- The "North America Office for Cracking Down on Falun Gong" (abbreviated as "Anti-Falun Gong North America Office" or similar) has been clearly identified as a subordinate branch under this joint operation system. This branch already existed before March 2021, and this time it was upgraded from its original division-level status to deputy bureau-level.
- The document shows that the Chinese Communist Party (CCP) began escalating its deployment of actions against overseas Falun Gong at least as early as 2021. This appointment reflects adjustments made by the CCP in organizational structure, personnel arrangements, and task deployments to intensify efforts to suppress Falun Gong overseas. This also confirms that the escalation of transnational repression against Falun Gong in the United States in the spring of 2024 is closely related to this deployment.
- This is the first time internal CCP personnel appointment materials have revealed the possibility that a relevant CCP agency might have been established on U.S. soil or in North America, and that it conducts and organizes transnational repression activities locally. This necessarily requires concealment from the judicial and administrative authorities of the United States and the host country.
- This agency is subordinate to both the CCP’s public security and the state security systems, indicating that its operations are not local or individual actions but rather a highly centralized, coordinated, national-level, cross-departmental operational model. This aligns with the CCP's top-level approach to handling issues of "overseas political security."
- Wu Xiuhua has long been involved in the persecution of Falun Gong. This personnel appointment and the promotion of the organization's status serve as preparation for his overseas deployment. This underscores the CCP's shift in targeting Falun Gong persecution abroad.
- The appointment document confirms the internal intelligence shared by Australian legal scholar Yuan Hongbing with the Epoch Times: Before the 20th National Congress, Xi Jinping held a highly confidential meeting where he explicitly stated that the main responsibility for cracking down on Falun Gong worldwide would be assigned to the Ministry of State Security, with coordination among different departments.
- This appointment provides important context for Xi Jinping's closed-door meeting in October 2022, during which overseas operations were reassessed and further coordinated.
3. Entering the United States during a politically sensitive period carries strong political motives.
1) This appointment and deployment took place during a highly sensitive period right after the U.S. presidential transition. Joe Biden took office in January 2021. The appointment was finalized by late March, and Wu Xiuhua reportedly entered Mexico in April before arriving in the U.S. The tight timeline shows the mission was launched urgently during the American political transition.
2) As the pandemic was winding down, international scrutiny and investigations into the origins of COVID-19 were intensifying. The Epoch Times and NTDTV consistently covered the origins of the virus and accountability issues, directly targeting the CCP’s most sensitive political vulnerabilities. The appointment document itself notes: “During the pandemic, Falun Gong activities in North America became even more rampant,” revealing the CCP leadership’s acute concern and fear over overseas exposure of the pandemic truth.
3) The timeline of Wu Xiuhua’s appointment and arrival in the U.S. demonstrates that this operation was strongly driven by political motives.
Timeline
April 7, 2020
The Epoch Times and NTD released “Tracking Down the Origin of the Wuhan Coronavirus,” described as the first documentary on the “CCP virus.”[26] It was published on YouTube and Facebook. The film examined scientific data and featured interviews with leading scientists and national security experts, raising questions about the CCP's transparency and the origins of the pandemic.
October 27, 2020
The New York Times published “How the Epoch Times Created a Giant Influence Machine.” The article criticized the publication’s use of the term “CCP Virus,” stating it attempted to link the virus to the Chinese Communist Party. It deliberately portrayed “anti-CCP” as “anti-China.”[27]
January 20, 2021
On the day Joe Biden was inaugurated, China’s Ministry of Foreign Affairs announced sanctions against 28 Trump-era officials, citing interference in China’s internal affairs. The move was widely interpreted as symbolic retaliation and strategic signaling during the U.S. political transition.[28]
On the same day, YouTube cited “serious policy violations” and demonetized three flagship Epoch Times programs—American Thought Leaders, Crossroads, and Facts Matter. NTD News Channel was also affected. No detailed explanation was publicly provided.[29]
The State Department’s Global Engagement Center (GEC) Special Report “How the People’s Republic of China Seeks to Reshape the Global Information Environment” (Sept 28, 2023) identifies YouTube as a key platform in the PRC’s effort to reshape the global information environment through coordinated information manipulation and malign influence activities. The PRC uses state propaganda, disinformation, inauthentic amplification networks, and coordinated online personas to promote CCP-aligned narratives while suppressing critical voices. These activities are designed to blend into organic discourse, leveraging digital advertising, content-sharing agreements, and algorithm-driven amplification to shape international perceptions and influence public opinion.[30]
April 12, 2021
Just two weeks after Wu Xiuhua was appointed, the Epoch Times’ Hong Kong printing warehouse was violently attacked. Four masked individuals armed with weapons forced entry, threatened staff, and smashed printing equipment. This was the second attack in two years (following a November 19, 2019, arson attack).[31]
April 25, 2021
Less than one month after Wu Xiuhua’s appointment, according to the Committee to Protect Journalists, Chinese authorities “detained and indicted 11 individuals for contributing to the Epoch Times,” who were formally indicted on April 25, 2021.[32] The U.S. Department of State condemned the arrests and urged Beijing to “release journalists and their contacts detained for reporting on COVID-19 restrictions” and to “cease its efforts to silence those who seek to report the truth.”[33]
The facts show how the CCP, right after the pandemic and during the U.S. power transition, exploited partisan divisions and media pressure to conceal this operation. The CCP was especially panicked and hostile toward global accountability for the pandemic’s origins and the Epoch Times’ truthful reporting. Believing past suppression of Falun Gong and the Epoch Times was insufficient, Wu Xiuhua personally went to the U.S. to orchestrate a larger-scale transnational crackdown to intensify efforts. While direct CCP involvement in Bill Guan’s prosecution cannot be proven, there is an inseparable link between the CCP’s deployments, the Guan case, the sharp escalation of transnational repression in the 2024 U.S. election year, and the CCP’s behind-the-scenes strategy and intent.
III. Major Epoch Times Events and the Political Context of the Bill Guan Case
Here, we need to clarify the relationship between Falun Gong and the Epoch Times/New Tang Dynasty Media.
Falun Gong, also known as Falun Dafa, was founded by Mr. Li Hongzhi [34] and was first introduced to the public in May 1992. It is rooted in Buddhist tradition, centered on the principles of Truthfulness, Compassion, and Forbearance. The practice includes meditation, gentle exercises, and moral self-improvement. By the late 1990s, according to Chinese official sources and estimates from independent organizations, the number of people practicing Falun Gong in China was approximately between 70 million and 100 million.
In July 1999, the Chinese Communist Party (CCP) initiated a nationwide campaign to eradicate this cultivation practice. This campaign has involved extensive propaganda, arbitrary detention, imprisonment, and torture. Furthermore, according to long-term independent investigations conducted by the World Organization to Investigate the Persecution of Falun Gong (WOIPFG), the China Tribunal,[35] the International Coalition to End Transplant Abuse in China (ETAC),[36] as well as David Matas, David Kilgour, and Ethan Gutmann,[37] and further corroborated by formal resolutions and parliamentary hearings of the European Parliament,[38] the United States Congress,[39] and the British Parliament, [40]this persecution has also involved large-scale, state-directed live organ harvesting from Falun Gong practitioners, which has been determined to constitute genocide and crimes against humanity.
In response to China’s pervasive information blockade and censorship, some of Falun Gong practitioners overseas established independent media organizations, including the Epoch Times [41]and New Tang Dynasty Television (NTD).[42] From its inception, the Epoch Times has positioned itself as an independent, uncensored outlet countering CCP propaganda. Dedicated to reporting the truth, exposing evil, upholding justice, and giving voice to the vulnerable and those oppressed by authoritarian power. One of its most influential works is the Nine Commentaries on the Communist Party, a series of articles published in 2004, which triggered a global spiritual awakening movement in which hundreds of millions of people publicly declared their withdrawal from the Chinese Communist Party and its affiliated organizations.
However, the operational policies and editorial viewpoints of the Epoch Times and New Tang Dynasty Television do not represent Falun Gong (also known as Falun Dafa). As with any independent media organization or commercial enterprise, employees of these entities retain the personal freedom to hold religious beliefs of their choosing. Nevertheless, the media organizations themselves are governed by the professional standards and ethical norms of journalism and do not embody or serve as an institutional expression of any individual’s religious faith.
The Chinese Communist Party deliberately conflates the spiritual practice of Falun Dafa with these media entities, employing this misrepresentation with profoundly malign intent. On one hand, it systematically stigmatizes outlets such as the Epoch Times by applying pejorative designations such as “cult,” thereby inciting public hostility, fostering societal division, and affecting their isolation. On the other hand, it frames its campaigns against these media organizations as a legitimate political struggle against “hostile foreign forces.” Through this rhetorical strategy, the Party seeks to confer an appearance of legality upon its severe persecution of Falun Gong adherents, while simultaneously concealing the genocidal nature and crimes against humanity inherent in such systematic repression.
|
Date |
Major Events |
Significant Meaning |
|
2000 |
John Tang founded Dajiyuan (Chinese Epoch Times) in Atlanta basement. English edition online 2003, print 2004. NTD Television founded 2001.[43] |
Established independent, uncensored media for Chinese audiences, later expanding globally to promote free and uncensored information. |
|
2003 |
First media to report true facts about SARS in China.[44] |
Broke censorship to protect public health and right to know. |
|
2004 |
Nov 19: Published "Nine Commentaries on the Communist Party."[45] |
Sparked massive CCP withdrawals; exposed the Party as anti-universe, anti-humanity, anti-traditional. |
|
2006 |
Mar: First to exposed CCP live organ harvesting from Falun Gong practitioners (Sujiatun camp revelations).[46] |
Drew worldwide attention to state-sanctioned organ harvesting and Falun Gong persecution. |
|
2012 |
Ms. Guo Jun, Editor-in-Chief of the Epoch Times, was invited to speak at an international human rights discussion held on September 18, chaired by Ms. Laura Dupuy Lasserre, President of the United Nations Human Rights Council.[47] |
This was the first time that allegations of the Chinese Communist Party’s forced organ harvesting of Falun Gong practitioners—first exposed by the Epoch Times in March 2006—were publicly raised at a United Nations human rights forum, drawing global attention. |
|
2013 |
Jun 21: Matthew Robertson won Sigma Delta Chi Award for organ harvesting reporting.[48] |
Validated Epoch Times' investigative journalism on major human rights abuses. |
|
06-07-2018 |
Published "How the Specter of Communism Is Ruling Our World" series.[49] |
Extended critique of communism as an evil force destroying traditional values and global order. |
|
2020 |
Apr: NTD & Epoch Times released documentaries on CCP virus origins and cover-up.[50] |
Exposed CCP's role in pandemic origins and global cover-up; emphasized accountability. |
|
2023 |
Jul 13: "RECOGNIZING THE EPOCH TIMES" entered into Congressional Record.[51] |
Official U.S. Congressional acknowledgment of contributions to truth, freedom, and exposing authoritarianism. |
The record demonstrates that the Epoch Times has, over more than two decades, played a sustained role in exposing Chinese Communist Party censorship, human rights abuses, and ideological operations, repeatedly addressing issues directly sensitive to the CCP’s political legitimacy. These activities progressively elevated the outlet’s influence within U.S. public discourse and policymaking circles, culminating in its formal recognition in the U.S. Congressional Record in 2023.
As the Epoch Times continues to expand its readership and international influence, evidence indicates that the Chinese Communist Party (CCP) has correspondingly intensified coordinated efforts to suppress and undermine the outlet. These actions reflect a broader, state-directed strategy to eliminate the Epoch Times media group entirely, which the CCP perceives as a threat.
It is precisely against this highly politicized backdrop that legal actions targeting the senior management and key affiliated individuals of the media outlet (including Chief Financial Officer Bill Guan) should be subject to a higher level of careful scrutiny and independent verification.
IV. Evidence from Leaked CCP Documents Indicating the Bill Guan Case as Part of an Overseas Strategic Deployment
This section systematically compiles leaked internal Chinese Communist Party (CCP) documents and official speeches from 2003 to 2025 that explicitly mention transnational repression operations targeting the Epoch Times, New Tang Dynasty Television (NTD), and other related media organizations and individuals. Together, they reveal a more-than-two-decade-long trajectory of continuous, institutionalized overseas repression. This demonstrates that the Bill Guan case is by no means an isolated or coincidental judicial incident, but rather one link in this prolonged chain of repression.
|
Date /Source/Departments |
Core Targets/ Methods |
|
2003–2004 (Hao Fengjun leaks) In summer 2003, MPS Bureau 26 (now Bureau 4) launched special investigations into the Epoch Times in 6 provinces/cities. Expanded to 9 provinces in 2004.[52] |
The targets of intelligence gathering were journalists, columnists, contributors, and contacts in China of the three media outlets. The MPS (the Ministry of Public Security) decided to merge the three cases of the epoch Times, the New Tang Dynasty TV, and the Sound of Hope Radio into one special case, still under the purview of the 26th Bureau, and expanded the task forces to nine provinces in China. Public Security Bureau (PSB) of Tianjin had already ordered special agent with codename “102” to infiltrate the Hong Kong branch of the Epoch times.[53] |
|
06-30-2005 (Liu Jing’s speech) A member of the CCP Central Committee, Vice Minister of the MPS, and the Director of the Central 610 Office [54] |
“This propaganda system, formed with the Epoch Times/New Tang Dynasty Television (NTD)/Sound of Hope Radio and Minghui.org as the main components, has served as a platform directing and coordinating various overseas and enemy forces. These facts have indicated that “Falun Gong” has become the core, trouble-making center of overseas anti-China and anti-CCP forces. It has become the political opposition faction and the core of overseas enemy forces. |
|
2015 (Dandong document leak)Political and Legal Affairs Commission of the Dandong; Dandong Municipal Stability Maintenance Office Municipal Committee; Dandong Municipal Comprehensive Social Management Office [55] |
Notice on the Issuance of the “14 Provisions on Stability Maintenance Response and Handling Work” — Relevant Foreign-Related Content: Focus on closely monitoring the activities of overseas Falun Gong and related groups; strictly prevent the reception and dissemination of New Tang Dynasty Television (NTDTV) programs and similar content. Strengthen internet surveillance, and block and delete Falun Gong–related information on the internet. |
|
2015 (Xiangkou leaked No. 31 Document) CCP Xiangkou Township Committee Office, Shiyang Yunxi, Hubei Province [56] |
Two main tasks: “First, comprehensively and systematically collect the information of “Falun Gong” personnel who belong to this local government’s jurisdiction and are living overseas, including the headcount, their headshots, passports, information of household registration, familial relationship network. Obtain the information of their relatives and workplaces. Second, based on the information collected of the headcounts inside and outside China, as well as their domestic personal network, develop individually customized work plan, report to higher authorities’ level by level, and carry out the next steps after being approved by the upper-level 610 Office.” |
|
12-25-2015 (Meng Jianzhu's Address at the Central 610 Office All-Cadre Meeting) Meng Jianzhu was a Politburo member, Secretary of the Central Political and Legal Affairs Commission, and Head of the Central 610 Leading Group [57] |
"The fight against Falun Gong is a serious political struggle against Western anti-China forces." "Target high-activity countries (esp. USA) as main battlefields, Li Hongzhi and leaders as key targets, and sever domestic-overseas links. Expand overseas operations with 'one country/one policy, one person/one policy' tactics to squeeze Falun Gong's foreign space." "Leverage Western demands on China to push bans/restrictions, destroy bases, sponsors, and partners, and gain initiative in overseas anti-cult efforts." "Priorities: (1) online struggle, (2) overseas struggle. Boost cyber defenses and countermeasures." "Emphasize intelligence for more precise, effective strikes." |
|
04-22-2016 (The Key Points of the Leading Group Work) Zhanjiang Municipal Committee Leading Group, Guangdong Province [58] |
"Verify and investigate Falun Gong online activity leads; decisively eliminate 'technicians,' 'information handlers,' and 'writers.' Sever overseas headquarters' internet infiltration channels into China. Prioritize intelligence collection on core domestic and foreign figures. Build secret networks inside and outside China, draft long/medium/short-term collection plans, leverage all departments, and integrate domestic/foreign, overt/covert, and online/offline operations." |
|
04-28-2016 (Leaked Doc.) Heshan District Committee (Yiyang Municipality)[59] |
“Coordinate domestic and overseas fronts, online and offline battlefields.” “Strengthen intelligence work and fully leverage its leading role.” “Determine the baseline number of Falun Gong and other cult members; improve the Falun Gong database; create a database for overseas Falun Gong; establish systems for routine maintenance, upgrading, and downgrading to ensure prompt inclusion of unregistered or repeat cases, timely downgrading of transformed individuals, adjustment of exonerated ones, and precise, real-time data updates.” |
|
03-31-2017 (Leaked document) CCP (Henan) Provincial Committee, Xianyang Municipal Party Committee 610 Office [60] |
“Integrate domestic and overseas, online and offline efforts.” “Actively develop secret assets to obtain insider, operational, and early-warning intelligence.” “Fully leverage foreign sister-city channels to improve quality and severely restrict Falun Gong’s overseas activity space.” “Excavate and cultivate non-governmental resources and forces, mobilize influential patriotic/friendly experts, scholars, journalists, and overseas Chinese leaders in the US/West to speak out, striving for more favorable coverage in foreign media.” “Closely target overseas core leaders, headquarters, and foreign politicians; meticulously plan strategic attacks, discord, and division.” |
|
07-11-2017 (leaked Shaanxi document) Li Zhongxiang, Deputy Secretary-General of the Xianyang Municipal Committee of Shaanxi Province and Director of the 610 Office [61] |
“We must carefully win the key overseas struggle.” “On one hand, make full use of foreign-related resources: Leverage sister-city platforms for targeted projects; Use visits by foreign dignitaries for publicity work; Deploy overseas economic entities to suppress Falun Gong’s economic and cultural operations and weaken their disruption capacity financially. On the other hand, strengthen overseas screening and persuasion efforts. “For leaders and core members of overseas Falun Gong organizations, media, Shen Yun Performing Arts, and related troublemaking groups—place them on a public blacklist and carry out precise targeted strikes.” |
|
12-14-2018(Luxi County) Luxi County (Pingxiang City) government [62] |
"Use secret agents to infiltrate and monitor core Falun Gong figures domestically and abroad to obtain their organizational structure and member details. Employ cyber operations to gather in-depth intelligence from overseas websites and email accounts of Falun Gong personnel. For key overseas Falun Gong backbone members from our town, combine two approaches: Divide and disintegrate through emotional persuasion, political appeals, and educational admonition; Deter and strike by leveraging their domestic assets (real estate, pensions, medical insurance, bank deposits, etc.) as pressure points." |
|
2018 (Leaked Document) Liaoning Provence local 610 Office [63] |
Target “Falun Gong” anti-propaganda sites such as the Epoch Times and NTDTV to deeply trace online political rumor sources and severely crack down on domestic “leakers.” Focus on Minghui.org and local Minghui periodical editions to identify and strike core members including regional editors, writers and information agents. |
|
11-20-2018 (leaked Special operation plan Plan) Lanchao Township’s special operation plan to prevent and combat “Falun Gong.”, Pingchang County, Sichuan Province [64] |
"Crack down on illegal online activity. Target Pingchang-related content on Minghui, Epoch Times, and NTDTV: open special cases, trace rumor sources, and severely punish key Falun Gong figures (tipsters, editors, writers, informants). Focus on WeChat, QQ, Weibo: uncover rumor-spreading groups, strictly punish creators/admins/key spreaders per law, and quickly shut down or block related groups and accounts." |
|
11-05-2024 (The Epoch Times obtained an internal document from the CCP’s public security system.)[65] |
The CCP has targeted 9 Epoch Times China News editors/reporters for surveillance, possessing their real names, IDs, hometowns, contact info, WeChat IDs, etc. Monitoring started December 2022—as China's 3-year pandemic lockdowns ended. All nine had reported on the mainland pandemic. |
The leaked CCP documents reveal six key features:
- Top-level political warfare — Special inter-agency task force labels the Epoch Times as the “core of overseas enemy forces” and command “platform.” Suppression of Falun Gong is defined as “a serious political struggle” against “Western anti-China forces,” targeting key members and headquarters.
- Long-term continuity — Over 20 years of suppression, with clear escalation of transnational operations in 2024.
- Highest-level coordination — Coordinated and jointly implemented by several core agencies, including the Ministry of Public Security, Ministry of State Security, Central 610 Office, Central Political and Legal Affairs Commission, foreign affairs departments, and others.
- Intelligence-driven — “Intelligence first” approach using secret agents and “one-person, one-policy” tracking, with deep surveillance of overseas targets.
- Multi-front tactics — “Domestic & overseas, online & offline” operations combining economic pressure, lawfare, infiltration, division, and proxy agents; exploits Western societal needs and regulatory loopholes to dismantle long-term bases and funding sources at low cost.
- Geographic focus —Taking the United States as the primary battlefield and main infiltration target, while simultaneously expanding globally.
Core Strategy and Intent:
The Chinese Communist Party’s (CCP) transnational repression against the Epoch Media Group—including the Epoch Times and NTD Television—reflects a long-term, systematic political campaign and a typical manifestation of what Chinese strategists describe as “unrestricted warfare.” Operating through the United Front system, the CCP employs proxy actors, indirect manipulation, economic inducements, and other low-cost, highly covert tactics to conduct operations overseas. These activities are often disguised as domestic disputes, private litigation, or ordinary legal processes within the United States, enabling the regime to pursue the strategy of “using Americans to defeat Americans.”
The core objective is to “kill with a borrowed knife”—to shift the blame onto the United States while suppressing the international exposure of the CCP’s crime. Once successful, it will morally blackmail the United States, severely erode the foundations of its religious freedom and rule of law, thereby allowing the Chinese Communist Party’s crimes against humanity to spread globally, ultimately serving the CCP’s strategic ambition for global hegemony. If we simply regard this kind of transnational persecution as ordinary human rights violations and ignore the deep strategic design and unrestricted warfare nature behind it, we will very easily underestimate its true intentions and the potentially severe consequences.
The Bill Guan case, in terms of timing, target, methods, and effects, forms a clear structural correspondence with the Chinese Communist Party’s more than 20-year pattern of transnational repression. Although there is no direct evidence proving CCP manipulation, it is difficult to regard it as an isolated criminal case; rather, it is embedded within a systematic overseas strategic framework directed against Falun Gong and related media.
V. The CCP’s Attack Methods Against the Epoch Times and Their Inevitable Connection to the Bill Guan Case
The CCP's full-scale suppression of the Epoch Times and NTD. Below are a few key aspects:
1. CCP Cyber Operations Against the Epoch Times
The record indicates that the Chinese Communist Party (CCP) has conducted sustained, state-linked cyber operations against the Epoch Times since at least 2016,[66] employing hacking groups and Advanced Persistent Threat actors to disrupt operations, steal sensitive data, and surveil journalists during periods of heightened critical reporting. These activities—including DDoS attacks, targeted intrusions, and long-term malware surveillance—were transnationally coordinated, escalated between 2020 and 2025, and culminated in U.S. indictments of Chinese hackers,[67] supporting the conclusion that the cyber actions reflect a systematic campaign rather than isolated incidents.
2. Psychological Warfare Versus Physical Attacks, Threats of Violence, and Acts of Sabotage
The record reflects a sustained pattern of physical intimidation, vandalism, and sabotage targeting the Epoch Times and Falun Gong–related activities, carried out by individuals widely assessed to be acting as proxies rather than through overt state action. Documented incidents since 2019—including arson[68] and repeated attacks [69]on printing facilities in Hong Kong, assaults on journalists and practitioners, and harassment across the United States, Canada, and the United Kingdom—demonstrate a transnational campaign designed to intimidate media workers, disrupt operations, and deter reporting critical of the Chinese Communist Party (CCP).
On October 7, 2025, the Epoch Times headquarters received a suspicious envelope containing white powder and immediately notified law enforcement. The incident occurred amid an escalating pattern of threats and harassment targeting the outlet, including impersonation-based intimidation emails and cyberattacks. According to the report, such powder-filled mail contained clear elements of intimidation and was part of a broader campaign to increase pressure.[70]
3. Propaganda and Media Warfare
The record indicates that the Chinese Communist Party (CCP) has conducted sustained propaganda and disinformation campaigns portraying the Epoch Times and Falun Gong as illegitimate or dangerous, using state media, overseas proxies, and major digital platforms to undermine credibility and isolate supporters. Since at least 2019, these efforts have expanded into coordinated global influence operations—including social-media manipulation, amplification of hostile Western media narratives, platform suppression actions, and COVID-19–related smearing—demonstrating a transnational strategy to delegitimize targeted media rather than isolated reputational disputes.[71]
On November 4, 2025, former CCP intelligence agent Eric revealed that the Ministry of State Security’s Tenth Bureau (Overseas Security & Reconnaissance) has turned WeChat, Douyin, TikTok, Xiaohongshu, and similar platforms into a core ‘intelligence and operations infrastructure.’ It can directly access all user data—including private messages—for transnational surveillance, profiling, and targeted suppression of overseas Chinese, students, dissidents, and anti-CCP self-media. The bureau operates primarily abroad with a dual defensive-offensive mandate: preventing defections/recruitment of regime personnel overseas while actively dismantling perceived ‘anti-CCP activities’ to achieve near-total monitoring of Chinese diaspora communities. It coordinates state security resources (covert/official agents, comms interception, cyber tools), collaborates with public security and united front units, and builds a multi-domain network of technical surveillance, human penetration, physical disruption, cyberattacks, psychological operations, and grassroots mobilization. Commercial firms (‘commerce supports intelligence’) supply hacking and influence capabilities. [72]
Facebook banned all advertising from the Epoch Times. NTD Television, affiliated with the Epoch Times, was also banned from the platform. They alleged that the outlet had obscured its connection to ads promoting President Trump and conspiracy content. The fact was that the Epoch Times was running subscription campaigns but never ran any political “pro-Trump” ads.[73]
On Jan. 20, 2021—the day of the U.S. presidential inauguration—YouTube demonetized three flagship shows of the Epoch Times, as noted in the previous section. More than two years later, on May 19, 2023, Google escalated these actions by removing the Epoch Times from Google Discover and Google News, citing alleged violations related to “medical content” concerning COVID-19 vaccines.[74]
On April 9, 2025, Sarah Wynn-Williams, former Director of Global Public Policy at Facebook, now Meta, testified at a Senate Judiciary Committee Subcommittee on Crime and Counterterrorism hearing that she saw Meta “repeatedly undermine US national security and betray American values… to win favor with Beijing and build an $18 billion dollars business in China.” According to Wynn-Williams, she “witnessed Meta work ‘hand in glove’ with the Chinese Communist Party to construct and test custom-built censorship tools that silenced and censored their critics.” “They began offering products and services in China as early as 2014. That hasn’t stopped. Their own SEC filings from last year show that China is now Meta’s second biggest market.”[75]
U.S. lawmakers have sharply criticized Google for perceived ties to the CCP. Sen. Josh Hawley (R-MO) accused the company of a “long, disturbing pattern” of censoring content to appease Beijing, citing YouTube’s deletion of anti-CCP comments and past efforts like censored Google.cn and Project Dragonfly, stating it was “selling out American principles for revenue.”[76]
In 2019 Senate testimony, Gen. Joseph Dunford said Google’s China work gives the Chinese military a “direct benefit,” a claim Sen. Hawley used to highlight Google’s refusal of U.S. military AI contracts while aiding China.[77]
Bipartisan senators (Cotton, Rubio, others) charged that Google was “more willing to support the Chinese Communist Party than the U.S. military” and urged ending its Huawei partnership.[78] In July 2025, the House Select Committee on the CCP warned that Google’s platforms enable CCP-linked scams, causing billions in U.S. losses, and demanded stronger action against such threats.[79]
4. Legal and Transnational Repression[80]
The record indicates that the Chinese Communist Party (CCP) has extended domestic repression overseas by leveraging diplomatic missions, proxies, and legal mechanisms to target the Epoch Times and Falun Gong practitioners as perceived political threats.[81] Since at least 2019, this approach has included proxy litigation in U.S. courts, coordinated threats and intimidation across multiple countries, global surveillance of lawful activities, and extraterritorial legal pressure—collectively reflecting a pattern of transnational repression rather than isolated legal or security actions.
According to the U.S. Department of Justice, in 2023 two individuals acting at the direction of the government of the People’s Republic of China, and operating in the United States without registering as foreign agents, allegedly sought to bribe an Internal Revenue Service official and manipulate the whistleblower complaint process in an effort to revoke the tax-exempt status of an organization operated by Falun Gong practitioners. They were charged with acting as illegal agents of a foreign government and with bribery-related offenses.[82] In July 2024, both men pleaded guilty in the U.S. District Court for the Southern District of New York.[83] The case illustrates an attempt to use U.S. legal and administrative mechanisms to carry out transnational “legal warfare” targeting Falun Gong.
After the Bill Guan (Guan Weidong) case became public, a Chinese-American in New York was threatened by Chinese police for privately discussing CCP infiltration of the US, suppression of Falun Gong, and attacks on the Epoch Times. Police labeled him a “Falun Gong participant,” “suspect in subverting state power,” and “leader,” threatened a red notice and extradition, and said his file remained in his village for easy conviction. When he continued, officers visited his 84-year-old mother in Jinan, Shandong, warning that she would be taken for investigation if he did not stop.[84]
This case reveals two key points:
- It exposes not just individual intimidation, but the CCP’s coordinated, cross-border efforts to suppress overseas free speech, confirming the illegal existence and covert operations of offices like the “Anti-Falun Gong Office in North America” in persecuting people both inside and outside China.
- CCP leadership closely follows the Bill Guan case, deploys domestic and overseas resources to monitor and suppress it, and labels it “subversion of state power”—treating it as a national security/political issue rather than a routine legal matter. These further fuel strong external suspicions of political interference and the weaponization of the judiciary.
5. Diplomatic Warfare and the Weaponization of International Organizations
On September 22, 2025, during the United Nations General Assembly in New York, the United Nations denied press credentials to journalists from the Epoch Times and its sister outlet NTD, preventing them from accessing UN facilities and covering the event, even though both outlets hold established media accreditation and have previously covered UN activities.[85]
The Epoch Times article (November 5, 2025) reports that during President Trump's October 2025 Asia tour, the Epoch Times and its sister outlet NTD—despite receiving prior approved media credentials—were denied access to press events at the ASEAN Summit in Kuala Lumpur, Malaysia, and the APEC forum in South Korea, becoming the only pre-approved outlet excluded. Epoch Times editor-in-chief Jasper Fakkert said in a statement. “It is deeply concerning that the regime is able to exert influence over international groups such as the United Nations and ASEAN to target America’s fourth-largest newspaper.” [86]
The ICIJ’s China Targets investigation, published April 28, 2025, supports the view that the CCP weaponizes the UN to suppress outlets like the Epoch Times, using it as a “staging ground” for transnational repression, with 59 of 106 Chinese/Hong Kong/Macau/Taiwan NGOs with UN consultative status “closely tied to the government or Communist Party,” enabling them to “monitor, harass and intimidate” critics at venues like Geneva, while Beijing pressures host countries to restrict access and protests during high-level events to “silence perceived threats” worldwide.[87]
6. From Background Correlation to Structural Correspondence — A Point-by-Point Comparison Between the Bill Guan Case and the Suppression Pattern
The evidence presented in the above five sections collectively outlines the institutional framework of the Chinese Communist Party's (CCP) transnational repression. By comparing this framework point by point with the specific characteristics of the Bill Guan case, the following structural matches become evident:
(1) Match in Target Identity: Multiple internal CCP documents explicitly list key figures and high-level personnel of the Epoch Times as priority targets for attack; Bill Guan, as the CFO of the Epoch Times, is precisely one of the core leaders of The Epoch Times.
(2) Match in Timing: The indictment occurred during the 2024 U.S. election year, which highly aligns in timing with the CCP documents recording the deployment to "eradicate" Falun Gong by the end of 2024.
(3) Match in operational methods. Whistleblower disclosures indicate that legal actions initiated in the United States were intended to escalate “from one person to several people, and ultimately to Falun Gong as a whole. Once one case succeeds, more allegations and scandals will follow, ultimately destroying you.” Shortly after this case's indictment, multiple lawsuits against Shen Yun emerged, consistent with this pattern.
(4) March in a broader pattern of continuity, coordination, and consistency. More than 20 years of sustained repression, with various methods and multi-domain coordination all aligned.
Accordingly, the hypothesis of coincidence becomes difficult to sustain. The simultaneous presence of these four factors—each independently pointing toward the same target—significantly weakens the probability that the case is purely incidental.
It should be noted that the above analysis is based on high-level structural correlations rather than direct proof of causation. For this reason, the recommendation for an independent review, proposed in Part V of this report, is substantively necessary. Only through an independent investigation can the possibility of external involvement be definitively confirmed or ruled out.
Part Three: Introduction to Bill Guan
Bill Guan was born in 1962 in Guangxi, China, into a family of educators. During the CCP’s Cultural Revolution, his parents were publicly denounced and beaten, and his father was publicly killed by Red Guards in September 1968, when Mr. Guan was under six years old. Despite enduring political discrimination and poverty, he excelled academically, ranking first county-wide on China’s national college entrance examination in 1979. He later earned graduate credentials from Renmin University of China, and by 1993, he had become the youngest associate professor of accounting at Guangxi University and served as the director of the accounting teaching and research office.
In 1995, Bill Guan was a visiting scholar at the University of Wisconsin-La Crosse. There, he directly experienced the U.S. legal system and civil liberties, which sharply contrasted with CCP propaganda. Disillusioned with China’s political system, he immigrated to Canada in 1997. That same year, he began practicing Falun Dafa, guided by the principles of Truthfulness, Compassion, and Forbearance. He focused on improving his moral character and becoming a better, more considerate person. Practicing the five sets of exercises of Falun dafa greatly improved his physical and mental health.
After the CCP launched its nationwide persecution campaign in July 1999, Mr. Guan traveled to Beijing in December 1999 to peacefully appeal for freedom of belief. [88]He was arrested, detained, and forcibly deported, and has not returned to China since.
Starting July 20, 2001 (the second anniversary of the July 20 crackdown), Guan Weidong began a 330-hour silent sit-in and hunger strike in front of the Chinese Embassy in Canada, publishing “My Heart Is Bleeding” to demand an end to the “horrific and inhumane” persecution.[89] On August 27, he launched a second campaign to urgently call for rescue amid life-threatening conditions faced by practitioners in China, earning public sympathy and support from parliamentarians.[90] Since September, he has joined a 5,000+ km SOS walk across Canada, exposing CCP state terrorism against Falun Dafa practitioners and sharing the principles of Truth, Compassion, and Forbearance. The Canadian government awarded over 200 honors to Falun Dafa.[91] Through petitions, sit-ins, marches, and media outreach, Guan lit the torch of human rights, awakening Canadian society to the persecution of Falun Gong—his perseverance is an unyielding cry of conscience and a steadfast defense of freedom of belief.
During Bill Guan’s tenure as Chief Financial Officer of the Epoch Times, the English-language edition grew from a small-scale free newspaper into a nationwide subscription-based media outlet, with both its staff size and revenue increasing significantly. As its influence expanded, the outlet also faced sustained pressure from major technology platforms and coordinated public opinion attacks.
Mr. Guan’s family circumstances are modest and constrained: his wife has lived with a serious spinal disability for more than twenty years, and his adult son, who is autistic, resides in Canada and is unemployed. Since October 2024, Mr. Guan has not received any salary.
On June 2, 2024, Mr. Guan was arrested at his rented residence in New Jersey and transported to a detention facility in Brooklyn, New York. A multi-hour search of his home uncovered no significant assets or cash. Following the indictment, The New York Times and other outlets published reports alleging that he laundered at least $67 million for the Epoch Times Media Group, Shen Yun Performing Arts, and related entities. Mr. Guan categorically denies these allegations.
Bill Guan has no record of tax violations or criminal convictions, and he enjoys an excellent reputation among his colleagues and friends. The record establishes that Bill Guan’s background, political history, and professional responsibilities align closely with groups historically targeted by the Chinese Communist Party (CCP) for sustained repression. His survival of political violence in childhood, subsequent emigration, and continued association with Falun Gong–affiliated media place him within a well-documented category of individuals subjected to suppression beyond China’s borders.
As Chief Financial Officer of the Epoch Times, Mr. Guan played a central role in expanding an outlet that CCP internal materials repeatedly identified as a strategic adversary. In this context, legal actions directed at Mr. Guan raise substantial oversight concerns regarding potential transnational repression, misuse of legal processes, and foreign influence intersecting with the U.S. justice system, warranting heightened congressional scrutiny.
Part Four: Congressional Findings Further Undermine Confidence in the Fair Administration of Justice in the Bill Guan Case
Recent congressional reporting on the Chinese Communist Party’s Political Warfare[92] and influence operations raises serious concerns regarding whether justice was fairly and independently administered. The report identifies systemic deficiencies within the U.S. Department of Justice (DOJ) in addressing CCP-linked threats, including insufficient expertise and rigor to counter “unrestricted warfare,” the termination of the sole CCP-focused enforcement program (the China Initiative), and the adoption of country-agnostic enforcement approaches that dilute accountability for CCP-specific operations.
The report further documents a CCP doctrine of “elite capture,” defined as the systematic co-optation of political, business, academic, and media elites through financial incentives, access to Chinese markets, and reputational inducements. Congress explicitly states that there are “abundant examples” of elite capture across U.S. institutions, including federal agencies. This framework establishes that the weaponization of legal and regulatory processes through influenced institutions is not speculative, but a recognized feature of CCP political warfare.
Critically, the report identifies the DOJ itself as an institution affected by CCP influence operations, noting policy retreat, abandonment of CCP-specific enforcement based on uncorroborated claims, and approaches that obscure the CCP’s political warfare strategy. These findings do not allege individual corruption; rather, they document institutional susceptibility and strategic misjudgment acknowledged by Congress.
Applying the above congressional findings to the Bill Guan case can further strengthen the argument that the prosecution is suspected of being selective or abusive. This case occurs precisely in an area where the Department of Justice has already acknowledged systemic deficiencies—namely, the Chinese Communist Party’s political warfare, transnational repression, and lawfare. Advancing this case without adequately assessing the risks of elite capture, the background of CCP political warfare, and the problems within the Department of Justice itself that have already been identified by Congress not only undermines judicial integrity but may also jeopardize U.S. national security. Therefore, the case requires higher-level congressional oversight and judicial review.
Part Five: Conclusions and Recommendations
A. Conclusions
Based on a thorough review of the indictment, relevant legal elements, financial and corporate records, whistleblower reports, leaked Chinese Communist Party (CCP) documents, and a documented over twenty-year pattern of transnational repression, this report reaches the following conclusions:
- The SDNY indictment against Bill Guan is legally defective. The charging instrument fails to establish a required predicate offense, relies on undefined and unsupported allegations of “illegally obtained funds,” misstates or misapplies statutory requirements, and substitutes narrative inference for admissible evidence. As pleaded, the indictment does not satisfy the essential elements of money laundering, bank fraud, or false-statement offenses under federal law.
- The prosecution is narrative-driven rather than evidence-driven. Core constructs—including the alleged “MMO Team,” foreign operational hubs, and the criminalization of revenue growth—are unsupported by corporate governance records, forensic accounting, or transactional proof. Lawful subscription revenue and routine compliance-related communications are improperly reframed as criminal conduct.
- The Bill Guan case aligns with a documented pattern of CCP transnational repression and lawfare. For details, please refer to the Point-by-Point Comparison between the Bill Guan case and the suppression pattern.
- The U.S. legal system appears to have been exposed to exploitation as an instrument of foreign political warfare. Whether through manipulated narratives, turned insiders, selective information, or the omission of material geopolitical context, the prosecution risks functioning—intentionally or otherwise—as a downstream effect of CCP lawfare, thereby implicating U.S. sovereignty, judicial integrity, and national security.
- Continuation of this prosecution without independent review risks a grave miscarriage of justice. Proceeding on a legally unsound indictment while disregarding credible indicators of foreign political manipulation threatens core principles of due process, equal protection, and the rule of law.
B. Recommendations
In light of the foregoing findings, and in the interests of justice, national security, and constitutional integrity, the following actions are urgently required:
- Immediate dismissal of the indictment against Bill Guan, or, at a minimum, a comprehensive superseding review addressing the absence of a predicate offense, statutory defects, and material evidentiary deficiencies.
- An independent Department of Justice review to assess whether this prosecution was influenced—directly or indirectly—by foreign disinformation, lawfare tactics, elite-capture dynamics, or CCP transnational repression operations.
- Judicial scrutiny of selective prosecution and abuse of process, including whether similarly situated actors were treated differently and whether exculpatory geopolitical context was improperly excluded from charging decisions.
- Congressional oversight hearings to examine:
- the vulnerability of U.S. law enforcement and judicial processes to CCP political warfare;
- the use of U.S. courts as tools of transnational repression; and
- DOJ policy failures were identified in congressional reports concerning CCP influence and elite capture.
- Protection for victims of transnational repression, including Bill Guan, journalists, whistleblowers, and Falun Gong practitioners, consistent with U.S. human-rights obligations and national-security interests.
- Formal recognition that lawfare constitutes a national-security threat, and that prosecutions involving CCP-targeted individuals or organizations require heightened scrutiny to prevent the weaponization of the U.S. legal system.
Final Statement
If a prosecution fails scrutiny of the facts, procedure, or public interest, it not only violates the parties’ rights but also risks being exploited by external forces, turning the U.S. justice system into a tool to suppress religious belief and free speech, thereby undermining America’s founding principles.
Should the CCP’s transnational repression of Falun Gong and the Epoch Times succeed on U.S. soil, the consequences would far exceed one case: America’s moral authority and global credibility would suffer; religious freedom and citizens’ rights would erode; national security and democratic rule of law would face compromised; similar persecution would spread worldwide, deepening victims’ suffering and severely damaging international human rights and moral standards.
Therefore, this case goes far beyond a technical legal ruling. It tests whether the U.S. can uphold the rule of law when facing systematic foreign political warfare and transnational repression—ensuring the judiciary is not turned against those exposing authoritarian abuses. More fundamentally, such suppression has moved beyond human rights into matters of national security and sovereign independence.
This report doesn’t judge guilt or innocence. It asks one question: When a prosecution has core legal defects, matches a foreign regime’s documented strategy in timing and target, and the U.S. judiciary has already been flagged by Congress for systemic flaws—when all three align, what does it mean to move this case forward?
The most dangerous moment for a rule-of-law system is not when it is openly breached by external hostile forces, but when it is unknowingly exploited by them. America's rule-of-law foundation will not collapse because of a single case, but it can be quietly eroded by repeated, unexamined oversights.
World Organization to Investigate the Persecution of Falun Gong (WOIPFG)
Mail: PO BOX 84
New York, NY10116
Email:contact@upholdjustice.org
Endnotes:
[1] United States v. Guan, No. 1:24-cr-00322 (VM) (S.D.N.Y. June 3, 2024) (indictment), https://www.justice.gov/usao-sdny/media/1354021/dl.
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