Settled, neither admitted nor denied CN NASDAQ

Luckin Coffee: $300M Fabricated App Sales and Circular Cash Scheme

Fabricated store coffee orders through fake corporate customer vouchers and circular mobile app payments.

CASE PROFILE & BENCHMARKS

Target Issuer: Luckin Coffee Inc. (CN).
Fraud Period: January 1, 2020 to December 31, 2022.
Reported Overstatement: $311.0M.
Total Fines & Penalties: $180.0M.
Maximum Incarceration: No prison sentence.
Independent Auditor: Ernst & Young LLP.
Primary Schemes: fictitious revenue.
Enforcement Status: SETTLED (neither admit nor deny).

OVERSTATEMENT $311.0M USD reported

TOTAL PENALTIES $180.0M Civil & disgorgement

PRISON TIME None No prison sentence

FIRST ACTION September 20, 2022 Initial proceeding

DETECTION METHOD Regulatory Enforcement & Forensic Audit Discovery source

PRIMARY REGULATOR U.S. Securities and Exchange Commission CN

ACCOUNTING MECHANICS FOR THIS CASE

HOW IT WAS DONE

Without admitting or denying the findings, the respondents consented to orders establishing that The company manipulated its accounting records by executing schemes under fictitious-revenue. Financial reports filed with market regulators contained material misstatements that distorted true financial condition.

Applicable Scheme Classifications:

fictitious revenue →

CHARGED RESPONDENTS & OUTCOMES

1 NAMED PARTIES

Respondent	Role	Disposition & Judicial Outcome	Prison	Civil Penalty	O&D Bar
Luckin Coffee Inc.	ISSUER	Enforcement order and financial sanctions imposed.	None	$180.0M	No

RED FLAGS OBSERVED PRIOR TO DISCOVERY

EARLY SIGNALS

CASH FLOW TO NET INCOME DIVERGENCE 2020 Operating cash flow severely diverged from reported earnings

ENFORCEMENT ACTIONS & PRIMARY DOCKETS

PRIMARY SOURCE CITATIONS

foreign regulator ENF-2020-luckin-coffee

Filing Date: September 20, 2022

Enforcement Action: Luckin Coffee: $300M Fabricated App Sales and Circular Cash Scheme

Fabricated store coffee orders through fake corporate customer vouchers and circular mobile app payments.

Provisions: Securities & Corporate Law Compliance

Disposition: neither admit nor deny View Primary Record ↗

TIMELINE OF EVENTS

CHRONOLOGY

June 1, 2020 • Misstatement

Material accounting irregularities commenced.

September 20, 2022 • Enforcement

Regulators commenced formal proceedings.

FINANCIAL CRIME REFERENCE SERIES

Cross-Domain Investigation Network

Major corporate accounting scandals frequently intersect with parallel financial crime domains. For violations outside financial reporting scope, explore the companion reference libraries in our open research series:

How Scams Work ↗

Consumer fraud, advance fee fraud, romance scams, phishing, social engineering, impersonation

How Money Laundering Works ↗

Placement, layering, integration, trade-based money laundering, smurfing, shell companies, bank secrecy

How Sanctions Evasion Works ↗

OFAC enforcement, dark fleet shipping, transshipment hubs, export control violations, circumvention networks

How Market Manipulation Works ↗

Spoofing, pump and dump schemes, wash trading, front running, insider trading, benchmark fixing

How Tax Evasion Works ↗

Offshore tax havens, transfer pricing abuse, carousel fraud, undeclared foreign accounts, aggressive tax shelters