Risk Alert: Kevin Ling, the KK Connections Group and its logging operations in Papua New Guinea
Logging companies mentioned in this document:
- RIMBUNAN HIJAU (PNG) LIMITED
- SUPER GREEN LIMITED
- KK CONNECTIONS LIMITED
- HUGO SAWMILLING LIMITED
- KERAWARA LIMITED
- LOW IMPACT LOGGING LIMITED
- WILLIS-KENT LIMITED
- TIAN SUYN LIMITED
- K L CONNECTIONS LIMITED
- LALOANI NO. 8 LIMITED
- RICHARD GAULT INDUSTRIES LTD.
- WESTENDERS LIMITED
- TARAIWARA PTY. LIMITED
- CHAIN REACTION LIMITED
- G88 LIMITED
Concessions mentioned in this document:
RISK ALERT KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA
RISK ALERT AUTHOR AND CONTACT DETAILS
ACT NOW Limited
PO Box 5218, Boroko, NCD
Tel: +675 7715 9197
Email: info@actnowpng.org
Date of publication: April 2026
Cover image: Tropical rainforest logs from the Mengen FCA concession in East New Britain Province ready for export, 2023
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 1
SUMMARY
Business: The KK Connections corporate group
Principal shareholder(s): Kuok Tiang Ling (Kevin Ling), Han Hook See, Jiangfeng Zhang
Primary geographical areas of operation: East New Britain Province, Papua New Guinea.
Primary business areas: Forestry, agriculture, construction and manufacturing
LINKED COMPANIES IN PAPUA NEW GUINEA:
KK Connections Limited; K L Connections Limited; KKC Sawmill Limited; KKC Veneer Limited; KKC Veneer No.2 Limited;
KKC Balsa Limited; Laloani No.8 Limited; Westenders Limited; Chain Reaction Limited; G88 Limited; PL Connections Limited;
KKCV Supermarket Limited.
RISKS IDENTIFIED
Credible evidence collated in this report indicates there is an elevated compliance risk associated with certain KK Group
companies operating in Papua New Guinea due to: (1) historical corporate and personnel linkages with the Kerawara Group,
an operator subject to adverse judicial findings concerning unlawful logging and governance failures; (2) participation in
logging operations conducted under Forest Clearing Authority (FCA) permits, a licensing pathway identified in national
inquiries and sectoral reviews as presenting heightened risks of regulatory non-compliance; (3) documented concerns in
Commission of Inquiry proceedings regarding landowner consent processes linked to projects associated with KK Group
entities; (4) judicial findings declaring FCA permit 15-10 (Dengnenge ‘A’) invalid due to deficiencies in mandatory consent
verification procedures; (5) reported asymmetries in access to independent legal and technical advice affecting landowner
participation in certain project approval processes; and (6) satellite-image-supported civil society reporting raising questions
regarding the relationship between authorised agricultural development objectives and observed logging activity in selected
concession areas.
RELEVANT STAKEHOLDERS
Given the risks identified in this report, these findings will be of direct relevance to organisations with anti-money laundering
(AML), environmental compliance, and human-rights due-diligence obligations, with particular application to: (1) financial
institutions, including commercial banks, development finance providers, and non-bank lenders; (2) commodities traders
and timber purchasers; (3) corporate service providers and trust and company service professionals; (4) accounting and
audit firms; (5) legal advisers engaged in project structuring, financing, or concession support; (6) shipping companies,
freight operators, and port service providers involved in timber export logistics; and (7) machinery suppliers, infrastructure
contractors, and other service providers supporting forestry and associated agricultural concession projects.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 2
CONTENTS
EXECUTIVE SUMMARY 4
1. INTRODUCTION 5
1.1 WHY RISK ALERTS? 5
1.2 CRITERIA FOR SELECTING THE KK GROUP 6
1.3 REPORT STRUCTURE 7
2. KK GROUP CORPORATE STRUCTURE 8
2.1 CORE KK GROUP ENTITIES 8
3. IDENTIFIED RISK FACTORS 11
3.1 LEGACY RISKS: THE KERAWARA GROUP 11
3.1.1 Kerawara Group and KK Group - the Ties 11
3.1.2 Sir Hugo Berghuser and the Barnett Commission of Inquiry 13
3.1.3 Illegal Logging and Alleged Collusion with National Forestry Authority Officers 13
3.1.4 Ray Cheong and Contempt of Court 14
3.1.5 Review Findings Published by the Department of National Planning and Monitoring 16
3.1.6 Forestry and Conservation Project (FCP) Review Findings (2003) 17
3.1.7 DNPM Individual Project Review – TP 13-38 Buhem Mongi Busiga (2004) 18
3.1.8 Conclusion 18
3.2 CONTEMPORARY RISKS: THE KK GROUP 19
3.2.1 The Commission of Inquiry into Special Agricultural and Business Leases (SABL) 20
3.2.2 KK Group and Forest Clearing Authority Compliance 24
3.2.3 KK Group and Landowner consent 25
3.2.4 Conclusion 25
4. RISK EXPOSURE OF OUTSIDE ORGANISATIONS 26
4.1 FINANCE AND PROFESSIONAL SERVICES 26
4.2 VENTURE PARTNERS 27
4.2.1 Shin Yang Group 27
4.2.2. Ningbo Yongli 28
5. CONCLUSION 29
5.1 THE KK GROUP 29
5.2 THE WIDER CONTROL ENVIRONMENT IN PAPUA NEW GUINEA 29
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 3
EXECUTIVE SUMMARY
This Risk Alert examines the corporate structure, operational footprint, and compliance risk environment associated
with the KK Connections corporate group (“KK Group”), a Malaysian-owned forestry operator active primarily in East
New Britain Province, Papua New Guinea. It forms part of ACT NOW!’s ongoing programme to support risk-based
monitoring of forestry-sector participants operating within Papua New Guinea.
Papua New Guinea’s forestry sector is widely recognised as presenting heightened compliance risks. National and
international assessments have estimated that illegal logging may account for between 70% and 90% of exported timber
by value, while recent analyses suggest illicit financial flows associated with forestry crime may exceed revenues generated
through the legal timber market. Forest Clearing Authorities (FCAs)—a licensing pathway intended to support agricultural
development—have been identified in multiple reviews as presenting particular governance vulnerabilities where logging
activity appears to precede or substitute for genuine land conversion.
Against this sectoral backdrop, the KK Group was selected for review due to the scale of its operations and its
concentration within East New Britain Province, a region that has accounted for a substantial proportion of FCA-related
exports in Papua New Guinea over the past decade. Export monitoring data indicates that KK Group entities have ranked
among the largest log exporters nationally, including topping recorded export volumes in 2022.
The report presents a number of core analyses designed to assist frontline professionals monitoring risk in Papua New
Guinea’s forestry sector.
First, the report documents historical corporate and personnel linkages between the KK Group and the Kerawara Group,
a forestry operator whose activities were subject to adverse judicial findings and critical oversight-body observations
relating to unlawful logging, governance failures, regulatory breaches, and criminal contempt of court. From a compliance
perspective, such legacy connections between the two forestry groups may increase exposure to governance-continuity
risks where operational practices and institutional relationships persist across successor or affiliated entities.
Second, the report reviews evidence relating to aspects of the KK Group’s contemporary operations, particularly those
conducted under Forest Clearing Authority permits. Material examined by the Commission of Inquiry into Special
Agricultural and Business Leases (2011–2013), together with subsequent civil society investigations and judicial findings,
point to concerns in certain concession areas regarding landowner consent processes, licence documentation, and the
relationship between authorised agricultural development objectives and actual observed logging activity. While these
matters do not establish wrongdoing by the KK Group, they highlight features of the operational environment that
reasonably warrant enhanced scrutiny from an AML and due-diligence perspective.
Taken together, the material reviewed indicates that the KK Group operates at scale within a forestry governance
environment widely recognised as presenting elevated compliance risk signals. Its operational footprint is concentrated
in concession types and geographic areas that have been the subject of sustained regulatory and investigative attention.
Historical personnel linkages with earlier forestry operators subject to adverse judicial findings further contribute to a
composite organisational risk profile that warrants careful consideration by stakeholders applying risk-based monitoring
frameworks.
Consistent with the objectives of the Risk Alert series, this report is intended as an intelligence resource to assist
compliance professionals, law-enforcement agencies, and commercial counterparties in applying proportionate due-
diligence measures in relation to forestry-sector engagement in Papua New Guinea. It should be read as a contribution
to risk assessment, not as a determination of liability or wrongdoing.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 4
1.0 INTRODUCTION
1.1 WHY RISK ALERTS?
Anti-money laundering (AML) provides a critical framework for identifying, monitoring, and disrupting networks linked
to environmental crime. However, the effectiveness of AML depends in part on compliance professionals and law-
enforcement agencies having access to reliable intelligence on higher-risk sectors, activities, and actors. In practice,
such intelligence is not always readily available.
As a result, the Financial Action Task Force (FATF) argues that in specialist sectors such as forestry, civil society
organisations can play an important role in supplying actionable intelligence to the wider compliance community.1
This observation is particularly relevant to forestry activity in Papua New Guinea, where forestry and corporate data can
be difficult to access, verify, and assess from a compliance perspective.
This matters because Papua New Guinea is a region of high ecological significance, containing the world’s third-largest
rainforest and forming part of New Guinea’s globally significant tropical forest biome.2
Moreover, country-level risks associated with illegal logging in Papua New Guinea are widely regarded as substantial.
In its 2017 National Risk Assessment, the country’s central bank cited research suggesting that illegal logging may account
for “between 70 and 90 percent of the total product exported,” measured by value.3
Forest Trends’ Timber Legality Risk Dashboard classified Papua New Guinea within its highest risk category, assigning a
score of 83.4 out of 100.4
Recent international analyses have estimated that illicit proceeds linked to forestry-related crime in Papua New Guinea
may exceed revenues generated through the legal timber market. According to studies conducted by the UNODC Law
Enforcement Assistance Programme (LEAP), illicit financial flows from forestry crimes in Papua New Guinea are estimated
to amount to between 80% and 130% of the value of the licit timber market.5
Certain categories of logging licences have also been identified as presenting heightened AML and compliance risks. Over
the past decade, these concerns have centred largely on Forest Clearing Authorities (FCAs). Although FCAs are intended
under the Forestry Act 1991 to permit forest clearing for genuine agricultural or development purposes, available analyses
suggest they have at times been used to facilitate large-scale logging operations without corresponding agricultural
development or, in some cases, without adequate landowner consent.
Civil society investigations indicate that logs harvested under FCA permissions may account for approximately one-third
of Papua New Guinea’s total log exports and that such logs can present elevated risks of legal non-compliance.
Forest Trends observes that: “Forest clearance permits intended for agricultural development, often used as a pretext for
gaining access to timber, have become a major source of logs exported from PNG over the last decade. These permits are
frequently issued illegally and without transparency or due process, in particular violating laws around customary land
rights”.6 The same report further notes that “the clearance of primary forests, ostensibly for conversion to agriculture, has
increased dramatically and accounted for 20–30 percent of the volume of logs exported each year since 2010”.7
These conclusions are supported by the Bank of Papua New Guinea in its sectoral review of forestry. The Bank concludes,
“that no agricultural, economic, or other land use activities were developed on the areas cleared under these permits”.8
Illegal logging activities are prohibited and subject to penalties under the regulatory offence provisions of the Forestry
Act 1991.9
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 5
To support integrated risk monitoring by national and international stakeholders, Act Now! is publishing a series of Risk
Alerts focusing on specific forestry participants. These alerts identify operators where the scale, nature, location, and
operational characteristics of logging activities may indicate elevated levels of compliance risk.
Risk is not an accusation of wrongdoing. Rather, it is an estimation—based on environmental, organisational, and
personnel circumstances—of the potential for wrongdoing. The riskier the circumstances, the greater the potential for
wrongdoing. High-risk environments and/or high-risk actors therefore require enhanced levels of due diligence to ensure
that all operations are compliant with the law.
Therefore, this publication series does not make findings of illegality or criminal wrongdoing. Rather, it documents
indicators of elevated risk associated with particular forestry participants in Papua New Guinea, and it provides reference
to the underlying data sources on which those indicators are based. The publications are intended as an intelligence
resource to assist compliance professionals and law-enforcement agencies in applying risk-based monitoring, due-
diligence, and investigative scrutiny, set against the challenging monitoring environment in Papua New Guinea.
1.2 CRITERIA FOR SELECTING THE KK GROUP
This Risk Alert focuses on the KK Group, a Malaysian-owned forestry operator primarily active in Papua New Guinea’s
East New Britain Province.
There are several reasons for selecting this forestry participant for further assessment.
East New Britain has been among the top three provinces in Papua New Guinea for log exports over the past decade,
with a significant proportion of logs extracted under Forest Clearing Authorities (FCAs).10 Analysis of national export data
indicates that East New Britain accounted for approximately 45% of total FCA-related log exports in Papua New Guinea
between 2016 and 2023.11
IMAGE: Papua New Guinea’s East New Britain Province12
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 6
As in other regions of Papua New Guinea, reported irregularities have been identified in forestry projects in East New
Britain operating under FCAs. Investigations and satellite imagery have documented what appears to be extensive selective
logging under FCA permits, rather than forest clearance for agricultural development as required by law, particularly
within the Makolkol, Dengnenge, and Mengen areas.13 Court proceedings, including complaints concerning landowner
consent and alleged procedural irregularities in licence issuance, further indicate elevated systemic risk factors in East
New Britain.14
KK Group is one of the most active forestry participants in East New Britain and, more broadly, within Papua New Guinea.
The logging monitor Société Générale de Surveillance (SGS) observed that: “KK Connections Ltd group of companies
topped the [national] log volume export in 2022 with 273,126 m3 followed by Rimbunan Hijau (PNG) Ltd group of
companies with 261,404 m3”.15
Given the scale of the KK Group’s operations in a sector and province exhibiting elevated signals of risk, it was shortlisted
for further examination.
This involved an in-depth corporate mapping exercise drawing on contemporary and historical corporate filings from
Papua New Guinea and Malaysia. Data on shareholders, directors, managers, and related entities were tabulated and
incorporated into network diagrams. SGS monitoring data were then used to identify concessions associated with KK
Group entities and close affiliates. Together, this generated a structured map of relevant actors and operations. Each actor
and operation was subsequently examined using verified open-source intelligence, including Commission of Inquiry
reports and transcripts, court decisions, Ombudsman Commission reports, Auditor General reports, published research,
and media reporting. These materials were triangulated to develop a risk profile of the group.
1.3 REPORT STRUCTURE
This report is structured in four parts.
Section 2 outlines the corporate structure of the KK Group based on available registry filings and export monitoring
data. It identifies core entities and associated companies operating in Papua New Guinea and summarises the Group’s
organisational footprint within the forestry sector.
Section 3 examines identified risk factors relevant to the Group’s compliance profile. It first reviews legacy risk indicators
associated with the Kerawara Group, given documented historical personnel and operational linkages. It then considers
evidence relating to aspects of the KK Group’s contemporary operations, including material arising from Commissions
of Inquiry, judicial decisions, and civil society reporting concerning concession activity conducted under Forest Clearing
Authority permits.
Section 4 identifies areas of potential exposure for external organisations linked to KK Group operations, including
financial institutions, professional service providers, trading partners, and project collaborators. These relationships
are considered from a risk-based due-diligence perspective.
Section 5 summarises the report’s findings and highlights their relevance for stakeholders applying compliance,
monitoring, and enhanced due-diligence frameworks to the forestry-sector in Papua New Guinea.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 7
2. KK GROUP CORPORATE STRUCTURE
The KK Group comprises a cluster of related companies registered in Papua New Guinea and headquartered at Section
64, Lot 53, Seaview Village, East New Britain Province (see Table 1). The group operates primarily in logging, sawmilling,
veneer production, and agricultural activities.
The group was founded by Kuok Tiang Ling, who uses the anglicised name Kevin Ling. Ling is a Malaysian national based
in East New Britain Province and was previously a senior employee of the Kerawara Group, a Malaysian-owned forestry
operator active in the same province.
2.1 CORE KK GROUP ENTITIES
The KK Group does not appear to maintain a publicly accessible company website. No publicly available evidence could be
identified of annual reports or other forms of voluntary corporate disclosure online. Statutory filings are available through
Papua New Guinea’s corporate registry; however, these filings are limited to basic company information. Historical corporate
records predating the 2022-23 upgrade of the corporate register are not currently accessible.
The Papua New Guinea Forest Authority is legally required to maintain a public register of forestry licences and
participants. At the time of review, such a register was not publicly accessible.
As a result of these information constraints, the corporate structure of forestry operators in Papua New Guinea must be
reconstructed using the limited filings available through the national corporate registry administered by the Investment
Promotion Authority (IPA). These records can then be triangulated with export monitoring data published by SGS, which
allow forestry concessions and export volumes to be identified. Independent databases, including PNGi Portal, PNGi
Forests, and OCCRP’s Aleph, further supplement the limited official sources.
Through a manual corporate-mapping exercise drawing on available filings and databases, the core companies that appear
to comprise the KK Group or are closely affiliated, are outlined in Table 1.
IMAGE: Tropical rainforest logs from the Mengen FCA concession waiting for export, 2023
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 8
Table 1: KK Group entities and close affiliates, based on IPA corporate filing data collated during 2025
Business Incorporation Current shareholders Current directors Current Current
name date postal registered
address address
KK 25/01/2005 Han Hook See; Kuok Han Hook See; Jiangfeng PO Box 286, Section 64, Lot 53,
Connections Tiang Ling; Jiangfeng Zhang; Kuok Tiang Ling; Kokopo, ENB Seaview Village,
Ltd Zhang; Nassain Nakikus Nassain Nakikus Kokopo
KL 15/02/2015 Han Hook See; Jiangfeng Han Hook See; Jiangfeng PO Box 286, Section 64, Lot 53,
Connections Zhang; Kuok Tiang Ling; Zhang; Kuok Tiang Ling; Kokopo, ENB Seaview Village,
Ltd Ka Tai Lee; Chung Kui Law Ka Tai Lee; Chung Kui Law Kokopo
KKC 28/05/2015 Kuok Tiang Ling; Han Kuok Tiang Ling; Han PO Box 286, Section 64, Lot 53,
Sawmill Ltd Hook See Hook See Kokopo, ENB Seaview Village,
Kokopo
KKC Veneer 05/04/2019 PL Jaya Limited; KKC Dennis Lu Jing Ling; Lu PO Box 286, Section 64, Lot 53,
Ltd Sawmill Limited Kiong Ling; Lu Siong Ling Kokopo, ENB Seaview Village,
Kokopo
KKC Veneer 28/09/2021 Jiang Feng Zhang; Han Han Hook See; Chung PO Box 286, Section 64, Lot 53,
No.2 Ltd Hook See; Chung Kui Kui Law Kokopo, ENB Seaview Village,
Law; Kuok Tiang Ling Kokopo
KKC Balsa 23/09/2021 Chung Kui Law; Han Chung Kui Law; Han PO Box 286, Section 64, Lot 53,
Ltd Hook See; Kuok Tiang Hook See Kokopo, ENB Seaview Village,
Ling; Ka Tai Lee; Jiang Kokopo
Feng Zhang
KKCV 26/04/2022 Chan Pheng Lim Chan Pheng Lim PO Box 286, Section 64, Lot 53,
Supermarket Kokopo, ENB Seaview Village,
Ltd Kokopo
G88 Ltd 11/01/2000 Kuok Tiang Ling; Han Kuok Tiang Ling; Han PO Box 286, Section 64, Lot 53,
Hook See; Jiangfeng Hook See; Jiangfeng Kokopo, ENB Seaview Village,
Zhang; Ka Tai Lee; Chung Zhang; Ka Tai Lee; Chung Kokopo
Kui Law Kui Law
Laloani 02/04/2003 Kuok Tiang Ling; Han Kuok Tiang Ling; Han PO Box 286, Section 64, Lot 53,
No.8 Ltd Hook See; Jiangfeng Hook See; Jiangfeng Kokopo, ENB Seaview Village,
Zhang; Mary Aisa Zhang; Mary Aisa Kokopo
PL 13/11/2019 PL Jaya Limited Dennis Lu Jing Ling; Lu PO Box 286, Section 64, Lot 53,
Connections Kiong Ling; Lu Siong Ling Kokopo, ENB Seaview Village,
Ltd Kokopo
Westenders 14/08/2008 Kuok Tiang Ling; Han Kuok Tiang Ling; Han PO Box 286, Section 64, Lot 53,
Ltd Hook See; JiangFeng Hook See; JiangFeng Kokopo, ENB Seaview Village,
Zhang; Chung Kui Law, Zhang; Chung Kui Law, Kokopo
Ka Tai Lee; Nassain Ka Tai Lee; Nassain
Nakikus Nakikus
Chain 08/08/2016 Kuok Tiang Ling; Han Kuok Tiang Ling; Han PO Box 286, Section 64, Lot 53,
Reaction Ltd Hook See; Chung Kui Hook See, Chung Kui Kokopo, ENB Seaview Village,
Law; Ka Tai Lee; Nassain Law, Ka Tai Lee; Nassain Kokopo
Nakikus Nakikus
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 9
KK Group entities comprise companies predominantly engaged in timber harvesting, log export, and associated
agricultural and infrastructure projects in Papua New Guinea.
Corporate filings and testimony before the Commission of Inquiry into Special Agriculture and Business Leases (SABL
Commission) indicate that a relatively small and recurring group of individuals appear across multiple entities as founders,
directors, shareholders, or key personnel.
Kuok Tiang Ling (also known as Kevin Ling) is identified in SABL Commission proceedings as the founder and Managing
Director of key group entity, KK Connections Ltd.16 Ling confirmed to the inquiry that he had previously worked as a senior
employee of the Kerawara Group until approximately 2006, after which he established KK Connections Ltd.17
In his testimony, Ling described himself as the principal of KK Connections and outlined the company’s role as a developer
and contractor across projects in East New Britain Province.18 He stated that KK Connections was involved in road
construction, logging operations, and agricultural developments associated with SABL-related projects.19
Corporate registry records identify several key KK Group shareholders and directors, including Kuok Tiang Ling (Malaysian
national, born 02/1966), Nassain Nakikus (Papua New Guinea national, born 11/1955), Han Hook See (Malaysian national,
born 08/1963), and Jiangfeng Zhang (Chinese national, born 10/1976).
A fifth individual, Ray Chee Keong Cheong, was identified in a 2013 media report as General Manager of KK Connections
Ltd, following his participation in site inspections of KK Connections’ road and bridge construction works in the Inland
Baining area.20 Judicial and corporate records indicate that, prior to his reported role at KK Connections Ltd, Cheong served
as a Director at Kerawara Limited.21
Attention will now turn to the risks associated with KK Group entities or personnel.
IMAGE: Logging camp close to the Mengen FCA concession, 2023
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 10
3. IDENTIFIED RISK FACTORS
As one of Papua New Guinea’s most active forestry participants over the past fifteen years, and given its involvement in
large-scale round log exports, the KK Group is assessed as presenting a baseline moderate-to-high risk profile based on
systemic environmental considerations.
Risk is not an accusation of wrongdoing. Rather, it is an estimation—based on environmental, organisational, and
personnel circumstances—of the potential for wrongdoing. The riskier the circumstances, the greater the potential for
wrongdoing. High-risk environments and/or high-risk actors therefore require enhanced levels of due diligence to ensure
that all operations are compliant with the law.
This baseline profile for the KK Group reflects country-level estimates of illegal logging prevalence and documented
governance weaknesses in the forestry sector, including in East New Britain Province. These factors increase the likelihood
that forestry participants may be involved in improper activity. They do not constitute confirmation that any such activity
has occurred.
This preliminary risk estimate may be mitigated or heightened by group-specific indicators identified through further review.
This section summarises the available evidence supporting an assessment that the KK Group presents elevated
organisational risk indicators from a compliance perspective.
3.1 LEGACY RISKS: THE KERAWARA GROUP
This section summarises publicly documented risk factors associated with the Kerawara Group. Kerawara is a forestry
participant that is separate from the KK Group. It is included in the risk profile as Kerawara Group is reported to have
historical operational and personnel linkages with the KK Group.
3.1.1 - Kerawara Group and KK Group - the Ties
As noted, the KK Group has had historical operational and personnel linkages with the Kerawara Group, a Malaysian-
owned forestry participant that was particularly active during the 1990s and 2000s, with a concentration of operations in
East New Britain Province.22 The Kerawara Group’s principal entity was Kerawara Limited, registered on 27 August 1992.
Its operations were supported by related companies, including Hugo Sawmilling Ltd and Seribu Daya (PNG) Ltd, which
were involved in the harvesting, processing, and export of round logs. Other entities associated with the Kerawara Group
included Richard Gault Industries.
Corporate records, judicial decisions and Commission of Inquiry evidence indicate that Kuok Tiang Ling (also known as
Kevin Ling) and Ray Chee Keong Cheong held senior roles within Kerawara’s corporate network. When questioned at the
Commission of Inquiry into Special Agriculture and Business Leases (COI SABL), Kevin Ling stated that prior to 2006 he
had been employed by the Kerawara Group before establishing KK Connections Ltd.23
A decision of the National Court of Papua New Guinea records that Kevin Ling also served as General Manager of
related entity Hugo Sawmilling in or around 200124, while corporate filings show that Ray Cheong was a director of Hugo
Sawmilling between 2002 and 2004. Both Kerawara Limited and Hugo Sawmilling were engaged in logging and the export
of round logs.25 Politician and businessman Sir Hugo Berghuser was a shareholder in Hugo Sawmilling until 2001
(see 3.1.2).
Judicial records further indicate that Ray Cheong served as a director and senior officer within Kerawara-linked entities
in the late 1990s and early 2000s and was subsequently named in court proceedings relating to Kerawara’s forestry
operations.26
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 11
Table 2: Shareholders and Office Holders, Kerawara Limited, 1998-200627
Year Shareholders Directors Secretary
1998 You Hu Hwong (50%), Yih Wei Hwong (50%) You Hu Hwong, Yih Wei Hwong Hwong You Soon
(James Hwong)
1999 Tung Leh Ling (50%), Bin Lopidi Genol (50%) Tung Leh Ling, Bin Lopidi Genol Hwong You Soon
2000 Tung Leh Ling (50%), Bin Lopidi Genol (50%) Tung Leh Ling, Bin Lopidi Genol Hwong You Soon
2001 Kong Fah Chong (50%), Kee Hui Lim (50%) Kong Fah Chong, Kee Hui Lim, Boon Shin Kok Hwong You Soon
2002 Kong Fah Chong (100%), Kong Fah Chong, Ray Cheong, William Gary Hwong You Soon
2003 Kong Fah Chong (100%), Kong Fah Chong, Ray Cheong, William Gary Hwong You Soon
2004 Kong Fah Chong (100%), Kong Fah Chong, Ray Cheong, William Gary Hwong You Soon
2005 Kong Fah Chong (100%), Kong Fah Chong Hwong You Soon
2006 Kong Fah Chong (100%), Kong Fah Chong Hwong You Soon
Table 3: Shareholders and Office Holders, Hugo Sawmilling, 1998-200628
Year Shareholders Directors Secretary
1998 Sir Hugo Berghuser (51%), Kerawara Limited (49%) Sir Hugo Berghuser, Kong Fah Chong
1999 Sir Hugo Berghuser (51%), Kerawara Limited (49%) Sir Hugo Berghuser, Kong Fah Chong
2000 Sir Hugo Berghuser (51%), Kerawara Limited (49%) Kong Fah Chong
2001 Sir Hugo Berghuser (51%), Kerawara Limited (49%) Kong Fah Chong
2002 Yih Siang Hwong (51%), Kerawara Limited (49%) Kong Fah Chong, Ray Cheong, William Gary
2003 Yih Siang Hwong (51%), Kerawara Limited (49%) Kong Fah Chong, Ray Cheong, William Gary
2004 Yih Siang Hwong (51%), Kerawara Limited (49%) Kong Fah Chong, Ray Cheong, William Gary
2005 Yih Siang Hwong (51%), Kerawara Limited (49%) Kong Fah Chong
2006 Yih Siang Hwong (51%), Allan Wong Tin Chai (49%) Allan Wong Tin Chai Fausto Galamiton
Finally, until 2018, KK Connections Limited was listed within the Kerawara grouping in SGS log export monitoring reports.
IMAGE: Excerpt from the Log Export Monitoring Monthly Report for December 2017 to the Papua New Guinea Forest Authority.29
Consideration will now be given to factors affecting the risk profile of Kerawara Group.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 12
3.1.2 - Sir Hugo Berghuser and the Barnett Commission of Inquiry
Kerawara Group maintained historical ties with politician and businessman Sir Hugo Berghuser. From a compliance
perspective, such associations may give rise to heightened political exposure risk. These risks are amplified by the official
scrutiny of Sir Hugo Berghuser in the Barnett Commission of Inquiry.
In 1987, Justice Tos Barnett was commissioned to lead the landmark Commission of Inquiry into Aspects of the Forestry
Industry30. Forestry expert Dr Colin Filer summarised the Inquiry’s findings as follows: “The Barnett Inquiry found that the
logging industry of the 1980s was dominated by a set of unequal and unfair relationships between foreign (mostly Asian)
logging companies and ‘landowner companies’ that were typically established by local politicians to serve their own
personal interests rather than those of the majority of landowners in each logging concession.”31
During the course of the Inquiry, a number of proposed timber projects came to Justice Barnett’s attention that were
considered sufficiently serious to warrant Interim Report No. 7.32
This interim report documents evidence reviewed by the Commission indicating that Sir Hugo Berghuser MP’s company,
Superior Tropical Timbers, was at the time heavily indebted and in receivership. The Commission records that Sir Hugo
developed a proposal under which he would obtain a logging and marketing agreement to operate a Timber Rights
Purchase (TRP) area on the Rai Coast of Madang, with the intention that the TRP would subsequently be assigned to a
foreign developer.33 The Commission stated that the MP would “use his ‘good offices’ with the Ministers for Forests to
obtain approval to assign the contract to the selected contractor”.34
An internal document reviewed by the Commission indicated that the foreign operator would be incentivised through a
proposed transfer-pricing arrangement that could reduce Papua New Guinea tax liabilities on exported logs. In return,
“Mr Berghuser anticipated receiving K300,000 per annum once his contractual rights in the Rai Coast had been sub-
contracted ... this sum would be used by the bank to offset Sir Hugo’s substantial indebtedness”.35
Justice Barnett also referred to allegations of a conspiracy involving the then Forestry Minister and Tropical Timbers to
influence the contract tender process for operation rights over the Rai Coast TRP area by excluding two Malaysian bidders.
In his conclusions, Justice Barnett stated: “I regard Sir Hugo’s claim that he intends and has always intended, to carry
out or ‘control’ the operation himself, with the assistance of an unnamed American friend in Singapore as nonsense”.36
He further observed that “the clear references to proposed transfer pricing raise an element of criminal liability”.37 There is
no publicly available evidence that Sir Hugo Berghuser was subsequently prosecuted in relation to these matters.
From an AML perspective, any commercial relationship between a forestry operator and a politically exposed person (PEP)
may elevate corruption and governance risk exposure. This risk is heightened where official inquiries have raised serious
concerns regarding probity within the sector and the politically exposed persons role in that sector.
3.1.3 - Illegal Logging and Alleged Collusion with National Forestry
Authority Officers
Further risk indicators relevant to Kerawara’s profile emerge from a decision of the National Court of Papua New Guinea,
which found that Kerawara Pty Ltd and Richard Gault Industries Pty Ltd were involved in unlawful logging activities and
collusive conduct with national forestry officials.38
In Rafflin v Richard Gault Industries Pty Ltd & Kerawara Pty Ltd (1998), the Court recorded that Richard Gault Industries
Pty Ltd held Timber Licence No. 15-8 over the Warongoi Timber Area, while Kerawara Pty Ltd acted as its joint operational
partner.39 Justice Woods concluded that the two companies entered the land and removed timber without the consent of
the landholders, resulting in judgment against them for unlawful logging and trespass.40
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 13
Justice Woods further noted that both defendants failed to substantively engage with the proceedings:
“Whilst the 1st [Richard Gault Industries] and 2nd defendants [Kerawara Pty Ltd] did respond with
pleadings early in this matter they have failed to continue with pleadings or appear at mentions over the
past year or more in spite of being served with the process and the court has been forced to accept that
they are not interested in defending the claims.”41
The affected plaintiff leaseholders had acquired State Leases in 1991 over the relevant land portions under the Warongoi
Cocoa Block Scheme, described by the Court as “a project, planned by the Department of Primary Industry, the Provincial
Government and the Agriculture Bank for the economic development of the area into cocoa production by way of
smallholder blocks”.42
The Court found that, one year after the agricultural leases were issued, the Minister for Forests granted a Timber Licence
over the Warongoi Timber Area to Richard Gault Industries Pty Ltd without lawful authority. In 1993, the defendants
entered the plaintiffs’ land and “cut down and removed trees,” without separate consent from the plaintiffs.43
Justice Woods held that the State had no authority to issue a Timber Permit over the plaintiffs’ land and observed that the
National Forest Authority appeared to have “a very naïve understanding of land rights”.44
The judgment also addressed the relationship between the defendant companies and forestry officials, stating:
“There is evidence that the Lands Department officers in East New Britain had queried the right of the
defendant companies to enter onto and log the subject land, but they were overruled by officers of the
Department of Forests ... the defendant companies clearly acknowledge that they had no agreement
with the lessees to enter and log the land. The evidence suggests that the directors and other officers of
the two defendant companies colluded with officers of the Forest Authority to ignore the concerns of
the Lands Department officers and deliberately ignored the rights of the landowners and took timber
belonging to the plaintiffs”.45
On the basis of these findings, the Court declared:
“The first and second defendants were not entitled to enter onto the land of the plaintiffs and carry on
logging operations thereon. I declare that the first and second defendants logging operations on the
lands of the plaintiffs were unlawful. I order that the first and second defendants are restrained from
entering and carrying on logging operations on the plaintiffs’ lands. I find that there has been a trespass
by the first and second defendants, with the active encouragement and support of the Department of
Forests and the National Forest Authority, onto the lands of the plaintiffs and that the first and second
defendants are liable to pay damages to the plaintiffs for this trespass”.46
Richard Gault Industries Pty Ltd, Kerawara Pty Ltd, and the State were held liable for K2,306,611.81 in damages.47
3.1.4 - Ray Cheong and Contempt of Court
In Daiva v Pukali; Ome Ome Forests Ltd v Cheong (2002), the National Court found senior Kerawara-linked officers and a
Kerawara executive guilty of contempt of court after funds were withheld from a landowner company in breach of court
orders and payments were made to individual landowners rather than to the company itself.48 The Court held Ray Chee
Keong Cheong—who was later reported to hold senior roles within the KK Group—personally liable for contempt in relation
to breaches of consent orders concerning landowner royalties.49 The judgment further emphasised that the corporate veil
may be lifted where officers are responsible for unlawful conduct.50
The complainant was Ome Ome Forests Ltd, a landowner company. Ray Cheong, Jackson Hwong, and William Garey were
named as the first three defendants.51 Jackson Hwong was Managing Director of Kerawara Limited, while Ray Cheong and
William Garey were Directors of Kerawara Limited and Hugo Sawmilling Ltd.52
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 14
The Court observed that Ome Ome had entered into a forestry extraction and marketing agreement with Hugo Sawmilling
Ltd. Under that agreement, Hugo Sawmilling was required to pay Ome Ome royalties and premiums for each log extracted
and exported.53 The Court noted that Hugo Sawmilling acted as contractor and Kerawara Limited as subcontractor.54
A dispute subsequently arose concerning the management of Ome Ome, and legal proceedings commenced in 2001.55
During the proceedings, Hugo Sawmilling and Kerawara were ordered to withhold royalties and premiums pending resolution
of the dispute. They were subsequently ordered to release payments totalling K547,000 and to meet Ome Ome’s legal costs.56
Ome Ome alleged that these orders were not complied with despite service and repeated requests for compliance.57
Ray Cheong and Jackson Hwong denied knowledge of the relevant court orders. Justice Kandakasi rejected that defence, stating:
“I find that both Mr. Cheong and Mr. Hwong have deliberately failed to comply with the orders of this
Court especially, those made by consent on the 13th of July, which ordered the payments to be made
and released to Ome Ome. I find that, their claim of not being served is simply an attempt at trying to
avoid being found guilty of contempt.”58
With respect to William Garey, the Court found that payments had been made to individual shareholders of Ome Ome
rather than to the company itself. The Court accepted that divisions existed within Ome Ome concerning the contractor
and subcontractor arrangements. Justice Kandakasi held that payments were made to shareholders supportive of Kerawara
Limited and found Garey in contempt. He stated:
“I find further that his motivation was to please part of the management and the shareholders
[of Ome Ome] that were with him and his company and thereby sideline those who were against
him and his company.”59
The Court noted that Ome Ome’s legal fees had ultimately been paid and therefore excluded that issue from the
contempt findings.60
The three defendants argued that, because they were not parties to the original proceedings between Ome Ome, Kerawara
Limited, and Hugo Sawmilling, they could not be held personally liable. Justice Kandakasi rejected this argument, stating:
“... not only did the defendants fail to comply with the orders but they also have failed to retain [the
withheld moneys] and [instead] made payments to Ome Ome’s shareholders and not Ome Ome
despite the clear terms of the orders. There is no evidence of the defendants drawing to the board of
directors of the two companies as to the existence of the orders and the need to comply with them
or do something about them to avoid being in contempt. If however, this was done, there should be
a board decision regarding the compliance or otherwise of the orders but there is no evidence. This
is critical because the payments to the [favoured Ome Ome] shareholders were not payments to
the plaintiff [Ome Ome Forests Ltd] going by the separate legal personality principle. Consequently,
both HSL [Hugo Sawmilling] and KL [Kerawara] could still be liable to Ome Ome for the amounts
due to it but was wrongly paid to the shareholders. It could also amount to a fraud against these
two companies to the extent of the payment, which could land the defendants within the ambit of
section 421 of the Companies Act 1997. Since the conduct of the defendants were criminal in nature
both from the perspective of section 421 of the Companies Act 1997 [misusing company assets] and
the contemptuous conduct, I do not consider it appropriate that they should hide behind and take
advantage of the corporate veil .... I consider it appropriate to add to the list of circumstances in which
the corporate veil could be lift[ed], cases where a crime including contempt of Court is committed. It
does not really matter who the crime is committed against ... Applying this to the present case, I find that
the defendants were the persons who deliberately decided not to comply with the orders. Not only that,
they also chose to act in direct breach of the orders by failing to retain and pay to Ome Ome premiums
and other payments due to it. Instead, they chose to and did pay to persons not entitled to receive the
payments. This deprived Ome Ome of the amount of money due to it ... I find that the defendants have
been correctly named as the defendants to the contempt charges which have been established beyond
any reasonable doubt. I therefore return a verdict of guilty against them.”61
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 15
From a compliance and governance perspective, this judgment is significant. It records criminal contempt findings against
senior officers of Kerawara and Kerawara-linked entities, including Ray Cheong, who was later reported to hold senior
roles within the KK Group entities, including as a director of Loloani No. 8 Limited and as General Manager of KK
Connections Limited.62
Further adverse observations concerning Kerawara Limited were recorded during the 2002–2004 Department of National
Planning and Monitoring forestry review, which was supported by the World Bank. The findings are outlined in the
following section.
3.1.5 Review Findings Published by the Department of National Planning
and Monitoring
The Department of National Planning and Monitoring (DNPM) conducted a review of Papua New Guinea logging projects
in 2003. As part of that process, a report was issued concerning Timber Permit 3-27 (Iva Inika). The report identifies Imi
Development as the landowner company holding the Timber Permit over the Iva Inika area, with Kerawara Limited named
as the logging and marketing contractor.63 The field review was undertaken in July 2003, and the final report was issued in
November 2003 after stakeholders were reportedly given an opportunity to respond to preliminary findings.
Under the logging and marketing agreement, the DNPM noted that Kerawara Limited was required to pay royalties, log
export duties, reforestation levies, agricultural levies, and infrastructure development levies. Imi Development was
required to apply these levies toward reforestation, agricultural projects, and agreed infrastructure works.64 The agreement
also required Kerawara Ltd to construct specified roads and bridges and to deliver certain infrastructure benefits directly
to landowners.65
The review recorded a number of concerns relating to Kerawara’s compliance with permit conditions and regulatory
requirements. It was alleged in the report that: “The company appears to be operating without a current and valid
environmental plan”.66 The review further stated that there was no evidence that Kerawara had implemented the required
Environmental Monitoring and Management Programme.67
Kerawara was reportedly required under the Timber Permit to construct ten permanent bridges or concrete causeways.
The review team claimed that “there were no permanent bridges or concrete causeways sighted during the field visit”.68
The report also recorded that Kerawara had not allegedly upgraded the road from the Hiritano Highway to the Timber
Rights Permit area. The company reportedly stated that the relevant land was privately held and could not lawfully
be developed.
The review also documented landowner allegations that logging activities had taken place outside the Timber Rights
Permit area.
Further concerns were recorded in relation to regulatory compliance requirements. The report noted that: “The Forestry
Regulations require the lodgement of a Performance Bond and delivery of an original copy to the PNGFA Managing
Director. There is no evidence within the PNGFA files that Kerawara Ltd has complied with this requirement”.69
Concerns were also raised regarding employment practices. The report stated: “Logging camp and log pond personnel
included a significant proportion of expatriates. In some cases they were undertaking jobs restricted to PNG Citizens by
the Department of Labour and Industrial Relations, for example driving logging trucks”.70
The review further observed alleged structural governance weaknesses within oversight arrangements, noting that:
“PNGFA field staff have had to develop a close relationship with logging company field managers with respect to being
provided with accommodation, meals, etc”.71
Landowner representatives also raised concerns regarding communication and financial transparency. The report records:
“A particular concern raised by Imi Development Ltd officials is the lack of regular consultation between the company officials
and Kerawara Ltd on the financial status of the Landowner Company and records of log shipments in the last 6 months”.72
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 16
The report also recorded landowner claims that eight reserve police officers were present locally and were allegedly “paid by
Kerawara Ltd, who refer to the General Manager of Kerawara Ltd as their boss”.73 The Royal Papua New Guinea Constabulary
stated that the officers were present to monitor drug trafficking and address law-and-order concerns in the community.
Finally, women in the landowner community specifically voiced concerns regarding the “mis-use and abuse of royalty
monies by men” and a lack of community development from funds allocated to the landowner company.74
3.1.6 Forestry and Conservation Project (FCP) Review Findings (2003)
A 2003 independent Forestry and Conservation Project (FCP) Review, commissioned by the Government of Papua
New Guinea with World Bank involvement, examined three timber operations: Kiunga/Aiambak, Bonua Magarida,
and Simbali.75
The Review Team alleged significant breaches of the Forestry Act across all three projects. In relation to the Simbali project
in East New Britain Province, Kerawara Limited and Hugo Sawmilling Limited were identified as subcontractors, and SSG
PNG Services Limited was also reported to be participating in operations within the project area.76
The Review Team claimed that SSG PNG Services Limited, Kerawara Limited, and Hugo Sawmilling Limited were operating
under approvals issued to a different entity and were therefore allegedly operating “without legal right,” to an extent that,
in the Review Team’s assessment, could individually justify deregistration and disqualification from participation in the
forestry sector.77
This key finding was accompanied by a range of other conclusions.
The Timber Authority for Simbali reportedly authorised logging over 40 hectares, with a maximum harvest of 1,000 m3.
The Review Team found that “by January 2003 in excess of 34,000 m3 has been exported from Simbali,” with “more than
2,000 m3 of logs at the beach, apparently ready for shipment,” indicating that the approved harvest limit had potentially
been exceeded by “nearly forty times”.78
Although the Timber Authority was granted for a small-scale cocoa development, the Review Team found “there is little
evidence of the proposed cocoa development” and concluded that “what has been presented as a modest agriculture
development is in fact proceeding as a full scale logging operation”.79
The Review Team argued that: “The involvement of Kerawara Limited and Hugo's Sawmilling, as subcontractors, is in
breach of section 87(4)” of the Forestry Act, which prohibits subcontracting under a Timber Authority”.80
The review further stated that: “The harvesting and sale of logs from roadline clearing areas required a separately
approved TA and the failure to obtain this is in breach of the Act”.81
The Review Team also documented oversight concerns, noting that: “There appears to have been no attempt by the PNGFA
to advise the Chairman of the PFMC or the provincial minister of the known abuses in the Simbali area,” and that further
Timber Authority applications were being processed even after breaches had been identified.82
As a result of these findings, the Review Team recommended that “logging at Simbali” be halted; that “no further export
approval should be given”; that logs be “seized under section 123”; and that “an action for damages under section 127
should be commenced against Kerawara Limited and Hugo Sawmilling for the full value (with no deductions) of all logs
illegally harvested.”83 The Review Team also explicitly contemplated deregistration and disqualification from future
participation in the forestry sector.84 It is unclear what steps if any were taken by the state in response to these findings.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 17
3.1.7 DNPM Individual Project Review – TP 13-38 Buhem Mongi Busiga (2004)
The previously referenced Department of National Planning and Monitoring (DNPM) “Review of Current Logging Projects”
produced an Individual Project Review Report (IPRR) No. 3 for Timber Permit (TP) 13-38 Buhem Mongi Busiga, based on a
field review conducted in August 2003 and a final report was issued in March 2004.85
The Timber Permit holder and marketer was Low Impact Logging Ltd, with Willis Kent Ltd acting as logging contractor.
The report does not indicate that this project was a Kerawara operation; it is referenced here because the DNPM review
records Ray Chee Keong Cheong as a Director of Willis Kent Ltd and explicitly notes that he “is also a Director of Kerawara
Ltd”.86 Ray Chee Keong Cheong was subsequently reported to hold senior roles within KK Group entities, including as a
Director of Loloani No. 8 Limited and as General Manager of KK Connections Limited.
The DNPM review notes that although Willis Kent Ltd acted as logging contractor, “the responsibility for meeting the terms
and conditions of the Project Agreement and the Timber Permit remain with Low Impact Logging Ltd”.87
A number of compliance concerns were identified by the Review Team:
The Review Team described Willis Kent Ltd’s licence application as “flawed,” noting that the application specified the project as TP
13-31 Buhem Mongi, which had “expired on 4 January 1997... Despite these flaws, PNGFA issued the licence to Willis Kent Ltd”.88
The Review Team further stated that it asked “the company and the PNGFA for a copy of the logging and marketing
agreement (if any) but was not provided with one”.89 The absence of such documentation limited verification of third-party
contractual arrangements.
Although an Environmental Management and Monitoring Programme (EMMP) had been approved, the report records:
“There is an approved EMMP but as there is no Environmental Monitoring Officer employed on site, the programme is not
being followed or supervised for compliance”.90
With respect to the Wangidu sub-log pond, the Review Team reported that it was “created without DEC’s [Department
of Environment and Conservation] approval as required in the project’s Environmental Plan approval conditions”.91
The review also stated: “The Forestry Regulations and the Project Agreement require the lodgement of a Performance
Bond by Timber Permit holders. The Regulations require the delivery of an original copy to the PNGFA Managing Director.
There is no evidence within the PNGFA files that Low Impact Logging Ltd has complied with this requirement”.92
In addition, the report notes: “Under the terms and conditions of the Licence, Willis Kent Ltd is required to lodge a
performance bond. There is no evidence that this has been done”.93
Finally, the report relays landowner concerns over the close relationship between the contractor, Willis Kent Ltd, and
PNGFA officers: “Concern was also expressed over the close relationship between the PNGFA monitoring officers and the
expatriate personnel belonging to the Logging Contractor [Willis Kent Ltd]. Landowners would like to see PNGFA staff
totally independent of the Logging Contractor”.94
3.1.8 Conclusion
This section has documented corporate and personnel linkages between the Kerawara Group and the KK Group.
The legacy linkages between Kerawara and KK are relevant given that the KK Group was founded by Kevin Ling, who
previously is reported to have held a senior managerial role within the Kerawara Group, and was later joined at KK Group,
according to public records, by Ray Cheong.
From a compliance perspective, these corporate and personnel links may elevate the risk that operational practices and
governance approaches associated with one group could be replicated within successor or affiliated entities.
The historical material reviewed regarding Kerawara Group includes judicial findings and oversight reports recording
allegations and determinations relating to unlawful logging, governance failures, regulatory breaches, and contempt of court.
The data collected for this report indicates that several of these risk indicators documented in relation to the Kerawara
Group also appear in connection with aspects of the KK Group’s operations.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 18
3.2 CONTEMPORARY RISKS: THE KK GROUP
By the end of 2024, the KK Group of companies had exported approximately three million cubic metres of logs from sixteen
large-scale logging projects in Papua New Guinea since commencing operations in or around 2008. The majority of this activity
has been concentrated in East New Britain Province, which accounts for fourteen of the Group’s sixteen log export projects.
Table 4: Logging concessions tied to the KK Group95
Licence Type
Contractor/
Log Exports
Concession
Area (Ha)
Company
Acquired
Exporter
Province
Number
(years)
Licence
Year(s)
Parent
Period
E.N.B. Toriu 30,830 FCA 15-04 2008 10 KK CONNECTIONS KERAWARA LIMITED 924,221
Headwaters LIMITED
E.N.B. Makolkol 23,656 FCA 15-09 2016 5 K L CONNECTIONS KK CONNECTIONS 493,513
LIMITED LIMITED
E.N.B. Dengnenge 'A' n/a FCA 15-10 2016 8 LALOANI NO. 8 KK CONNECTIONS 314,324
Int. Agric Project LIMITED LIMITED
E.N.B. Dengnenge B n/a FCA 15-16 n/a n/a K L CONNECTIONS KK CONNECTIONS 184,118
Agro Forestry LIMITED LIMITED
E.N.B. Utnari Land n/a FCA 15-21 n/a n/a KK CONNECTIONS No parent 184,286
Agro-Forestry LIMITED
E.N.B. Suikol n/a FCA 15-13 n/a n/a WESTENDERS KK CONNECTIONS 15,711
LIMITED LIMITED
E.N.B. Taraiwara 22,800 FCA 15-14 2018 10 KK CONNECTIONS No parent 403,958
(Ext) Agro LIMITED
Reforestation
E.N.B. Inland Lassul n/a FCA 15-11 n/a n/a KK CONNECTIONS No parent 7,859
Baining LIMITED
E.N.B. Mengen n/a FCA 15-22 n/a n/a KK CONNECTIONS No parent 77,214
Integrated LIMITED
E.N.B. Makolkol n/a TA 15-90 n/a n/a K L CONNECTIONS KK CONNECTIONS 18,788
Kamarere LIMITED LIMITED
E.N.B. Vunapalading n/a TA 15-94 n/a n/a KK CONNECTIONS No parent 2,266
Teak Plantation LIMITED
Central Ormand Lako 19,621 TRP 03-30 1988 40 SUPER GREEN KK CONNECTIONS 161,248
LIMITED LIMITED
E.N.B. Seraji & 31,850 TRP 15-58 1970 40 KK CONNECTIONS No parent 275,220
Extension LIMITED
E.N.B. Inland Pomio 63,668 TRP 15-49 1989 40 KK CONNECTIONS No parent 1,576
(Galae) LIMITED
E.N.B. Inland Pomio 63,668 TRP 15-49 1989 40 CHAIN REACTION KK CONNECTIONS 12,584
(Galae) LIMITED LIMITED
W.N.B. Extended 57,100 TRP 14-41 n/a n/a G88 LIMITED KK CONNECTIONS 20,225
Mengen LIMITED
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 19
The company has also commissioned a veneer facility, KKC Veneer Mill, in East New Britain. When fully operational, the
mill is reportedly expected to process approximately 200,000 cubic metres of logs annually and to produce veneer, wood
chips, pellets, and plywood.96
The KK Group’s logging activities have primarily been conducted under Forest Clearing Authority (FCA) permits issued
pursuant to the Forestry Act 1991.97 Logging under FCA permits is legally permissible where forest clearance is incidental
to an approved agricultural or development project. FCAs are not intended to be issued for the primary purpose of timber
extraction. The Act does not authorise selective logging under FCA permits, and permits may be suspended where the
approved agricultural project is “not progressing according to the development plan or implementation schedule”.98
FCA projects account for approximately 84% of the KK Group’s recorded exports.99 Nearly one-third of total exports derive
from a single concession, the Toriu Headwaters FCA project, which generated 924,221 cubic metres of exports between
2008 and 2018.100
Other company operations have been conducted under Timber Authorities (accounting for less than 1% of exports) and
Timber Rights Purchase agreements (approximately 15%).101
One of the earliest systematic examinations of the KK Group’s forestry operations was undertaken during the Commission
of Inquiry into Special Agriculture and Business Leases (2011–2013).
3.2.1 The Commission of Inquiry into Special Agricultural and Business Leases
(SABL)
The 2013 Commission of Inquiry into Special Agriculture and Business Leases (SABL) was established in response to
mounting public concern that approximately 5.2 million hectares of customary land had been alienated through SABLs,
often in connection with agro-forestry projects that were alleged to lack adequate safeguards.102 The Commission reported
that the majority of SABLs reviewed were issued in breach of laws designed to protect the rights of customary landowners
and were associated with documented environmental and human rights concerns.103
The KK Group’s logging operations were referenced in the inquiry in connection with SABL leases 903C and 904C in East
New Britain Province, which had been issued to a locally owned company, Toriu Timber Limited.104 PNG export records
indicate that KK Connections Limited exported logs from the Inland Lassul Baining FCA (15-11) and the Toriu Headwaters
FCA (15-04), which appears to correspond to the FCA licences associated with the SABL land.105
According to testimony presented to the SABL Commission of Inquiry by Allan Balbal, who served as District Lands
Coordinator for Gazelle District in East New Britain, Toriu Timber Limited was closely involved in the preparation of
the Land Investigation Report (LIR).106 The LIR is a key document containing factual findings relating to customary
land proposed for an SABL, including ownership, boundaries, consent, and intended land use. Mr Balbal stated that
the landowner company “were chipping in” to cover expenses incurred by lands officers conducting awareness activities
and preparing the LIR.107
In a 2012 report, Greenpeace suggested that it was unlikely that Toriu Timber Limited — as a company reportedly owned by
local villagers — would have had the financial capacity to fund such expenses “without the direct financial assistance of
the proponent, Malaysian logging company KK Connections Ltd, which eventually acquired the sublease.”108 In evidence
to the Commission of Inquiry, KK Connections denied involvement in the landowner identification and consent process.109
The Commission of Inquiry also reported concerns regarding the authenticity of certain signatures on environmental and
land investigation documents submitted during the SABL approval process. During cross-examination, the Vice Chairman
of Toriu Timber Limited, Lucas Koatnaski, acknowledged signing documents on behalf of six different Incorporated Land
Groups (ILGs), despite being the chair of only one (Evar).110
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 20
Box 1: Excerpt from transcript: COI SABL, Transcript of Proceedings (Kokopo: Substantive Hearings, 9 November 2011).111
The Commissioner: Now, you look at that one, and you see how many times your signature appears under
different incorporated land group[s]. Are you the head of those 6 incorporated land groups?
Koatnaski: No.
The Commissioner: Then why did you sign for these ILGs instead of your own, which is Eval?
Koatnaski: Because [they are] my clan members in those areas.
The Commissioner: Do not worry about them in any where [any way]. They are different ILGs. You are
from Eval, is that right? And I am not interested to know whether they are your family line elsewhere. They are
different ILGs. Do you understand that you have no right to sign on their behalf? Do you understand that?
Koatnaski: I understand that but because before it is difficult to get [and] bring them together.
The Commissioner: It does not matter. You go and have them sign it. You have to climb mountains, you have
to climb mountains. If it takes 2 months, if it takes 2 years, you do it. You understand that?
Koatnaski: Yes I do.
The Commissioner: Now [do you] understand that what you did there was wrong?
Koatnaski: Yes.
The Commissioner: That could easily amount to the crime of forgery. You forged their consent. Do you
understand that?
Koatnaski: Yes.
...
Commissioner Jerewai: Counsel, specify the document. Let is go [us go] document by document. Let is
[us] do it very clearly so that the witness know[s] exactly which document he is responding to.
Q: Yes. When you were signing the lease lease-back instrument, and the Land Investigation Report and the
other one –
Commissioner Jerewai: Sub-lease with KK Connections. When you signed all these three documents,
and you signed off for other villages which are not your village.
Koatnaski: Because it is hard for them to come out so I had to sign on their behalf.
These reported irregularities and concerns regarding possible forgery raised broader questions about whether affected
landowners had provided informed consent to the SABL leases and the proposed agro-forestry operations. Evidence was
tendered to the Commission suggesting that consent had not been properly obtained. One statement read during the
inquiry asserted that the leases had been issued under “fraudulent circumstances”.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 21
Box 2: Excerpt from transcript: COI SABL, Transcript of Proceedings (Kokopo: Substantive Hearings, 28 October 2011).112
We the undersigned Qaqet formerly Baining, leaders and elders of the Qaqet-Baining tribe of the East New
Britain, duly swear on oath and declare that the granting of above portions under SABL, under forest clearance
license issued to the Toriu Timbers Limited was done without the informed consent of or generally consent
by the landowners. Portions 904C and 903C, milinch Pondo, fourmil Rabaul in the northwest Gazelle area
of East New Britain as per gazette number G37 dated 26 February 2010, spanning 11,240 hectares and
42,240 hectares respectively were approved under fraudulent circumstances. The gullibility of the traditional
landowners was taken advantage of by the facilitators. The initiator of the project is the East New Britain
Provincial Administration and KK Connections as the project developer. There was never any free prior and
informed consent described as FPIC given by the traditional landowners of the area as required by law for any
part of their land to be facilitated for the purpose of SABL. As well, we as leaders were never notified nor gave
consent for this huge land areas to be facilitated under SABL.
Questions were also raised over whether those landowner leaders that were involved directly in negotiations, had sufficient
independent advice. When Vice Chairman of Toriu Timbers, Lucas Koatnaski, was asked by the Commission about who
explained the sub-leasing benefits and conditions, the witness informed the Commission that it was the developer KK
Connections. When asked if they obtained independent legal advice, the leader confirmed they did from a law firm, but
one which also acted for the developer KK Connections.
Box 3: Excerpt from transcript: COI SABL, Transcript of Proceedings (Kokopo: Substantive Hearings, 9 November 2011).
The Commissioner: May I interrupt? And who explained these things to you?
Koatnaski: It is between us, the landowner groups and the developers.
The Commissioner: Translator ...
Q: So you did not receive any legal representative, a lawyer, to explain the contents?
Koatnaski: We got our lawyer who prepared this document.
Q: Okay, so who is your lawyer?
Koatnaski: Kivu and Associates.
Q: Yes, they are the ones that are actually on that particular document — they have actually prepared
that document.
The Commissioner: Kivu and Associates, sorry, it is on that document.
Q: It is on the document. It is separated — flip back a few pages and you will see the names and address.
The Commissioner: All right. Was Kivu and Associates your lawyers only, or KK Connections’ lawyer
as well?
Koatnaski: They are the law firm representing the developer and us too.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 22
The Commission noted with concern the potential information asymmetries and inequalities in business knowledge.
Commissioner Alois Jerewai stated:
“This seems to be the methodology of these people, including KK Connections, to represent [sub-lease] figures in a
way that is unclear to a person not of sufficient sophistication to be able to tell the difference. Take Mr Koatnaski.
He cannot even speak English and had to be examined with an interpreter, with English translated into Pidgin so
that he could understand. Yet he is the [Vice] Chairman of the Board of Directors of the landowner company, Toriu
Timbers. He represents figures without explaining what they are in the format that [KK Connections manager] Mr
Yayaa had presented...”.113
In summarising the evidence provided to the Commission of Inquiry, Commissioner Jerewai stated that the inquiry had
identified a number of issues affecting the validity of the SABL leases. These included landowners’ names being placed
on consent forms without their knowledge or agreement; the landowner company acting without the authority of the
landowners, and without prior consultation or consent, in entering into the sub-lease agreement with KK Connections; and
agricultural development plans being changed “five or six times” from one type of development to another without prior
consultation with relevant government agencies.114 The Commission also found alleged inconsistencies in the description
of the currency in relation to the payment of export levies, with different documents referring either to USD or Papua New
Guinean kina.
Finally, the Commission noted evidence of questionable agricultural development:
“Our agriculturalist visited the Toriu area where you claim to have this development. His name is Mr Simon Sipo, who
holds a degree in Agricultural Science. While he confirms that a road of reasonable standard has been constructed,
the agricultural development on both sides of the road is pathetic, to say the least. He observed numerous skidder and
tractor tracks, which indicate the extraction of your forests rather than agricultural development.”115
The Commissioner indicated that there was no clear agreement on what development would in fact be delivered following
forest clearance. He observed when addressing Lukas Koatnaski, the Vice Chairman of the landowner company Toriu
Timbers Limited:
“There is nothing in the agreement that speaks of the KK Connection as a developer that commits them to develop
your agriculture ... this sublease gives this people, KK Connection ... 60 years occupation of your land and because of
that they can go and take your timber ... yet you have not nailed them down to a specific agriculture development”.116
When challenged on these inquiry findings for a 2017 Global Witness report, Stained Trade, lawyers for KK Connections
maintained that the company and its subsidiary and related companies did not hold any SABL leases and that while
one of its logging operations was being carried out under an SABL held by a landowner company, this SABL had not
been declared illegal.117 KK Connections stated it and its related companies had not been involved in any illegal logging
operations in Papua New Guinea.118
In summary, the SABL Commission of Inquiry hearings indicate that significant asymmetries existed between the KK
Group and affected landowner communities in terms of expertise, information, and capacity. The evidence presented also
suggested that certain government offices were operating with limited resources and, in some instances, appeared reliant
on logistical or operational support from forestry operators.
Taken together, these structural factors arguably contribute to an elevated risk environment for logging operations, in which
landowning communities and oversight bodies face constraints in effectively monitoring activities or enforcing compliance.
Subsequent evidence has identified compliance concerns relating to aspects of the KK Group’s operations conducted under
Forest Clearing Authorities.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 23
3.2.2 KK Group and Forest Clearing Authority Compliance
Forest Clearing Authority (FCA) permits have generated sustained controversy in Papua New Guinea in recent years.
Published research and sectoral reviews have raised concerns that, in some cases, FCA permits are being used to facilitate
large-scale selective logging rather than forest clearance genuinely linked to agricultural development projects.119 There is
also documented evidence indicating that landowner consent processes have, at times, not been properly obtained.120
Following an extensive review of academic literature, government documentation, and data sources — including analysis
from Global Forest Watch — Forest Trends stated that in PNG “the failure of nearly all of these operations to result in
viable agricultural projects indicates they are being used to access timber while avoiding the rules for sustainable forest
management established under the Forestry Act.”121
A 2018 report by Global Witness, A Major Liability, documented case studies of alleged illegal logging in PNG and
highlighted potential reputational and regulatory risks for China’s timber sector as a major purchaser of PNG timber.122
Global Witness reported that its investigators visited two KK Connections logging sites in East New Britain Province — the
Malkolkol and Dengnenge FCA areas. According to the report, satellite imagery indicated patterns consistent with selective
logging rather than comprehensive forest clearance for agricultural conversion.123 Global Witness stated that “the absence of
large-scale agricultural clearance happening in those titles ... strongly suggests that these permits were obtained fraudulently.”124
Additionally, Global witness highlighted that Kerawara Ltd. exported timber worth over PGK 16 million (around USD
5 million) from FCA 15-10 in East New Britain Province in 2017, even though the operation appeared to involve logging
rather than agricultural clearance, in breach of the permit’s terms.125 PNG export records for 2017 show the exporter from
FCA 15-10 as Laloani No.8 Limited, which is listed as a member of the Kerawara company group.126
When responding to questions from Global Witness, legal representatives for KK Connections stated that FCAs 15-09 and 15-10
had been obtained following landowner consent and submission of applications to the Provincial Forest Management Council
and the National Forest Board.127 The firm further stated: “The current Managing Director of PNG Forest Authority (Papua New
Guinea Forest Authority) has given evidence testifying that there is no fraud or illegality on the grant of the FCA [15-09].”128
The legal representatives did not address the separate allegation that FCA 15-10 was being subject to selective logging
rather than forest clearance for agricultural development.129
Act Now! has also recently published a detailed analysis of the Mengen FCA project, the most recent FCA permit issued
to the KK Group.130 Entitled A New Forest Grab, the report outlines a number of significant concerns regarding the Mengen
FCA project. It states that although the project’s logging licence is formally linked to a proposed agricultural development,
available analysis indicates that the Mengen project is operating in practice as a large-scale logging venture, with selective
harvesting of high-value primary rainforest generating the principal revenue stream.131 The report questions whether the
proposed timber plantation and agricultural components are genuine and economically viable.132
The report further states that there is limited observable evidence of land clearance consistent with agricultural conversion
within the project area to date.133 In contrast, satellite imagery and field observations are cited as indicating extensive
selective logging activity across substantial portions of the concession.134 The report notes that selective logging is not
authorised under an FCA permit.135
While documentation suggests that certain landowners have provided signed consent, the report also records sustained
and documented opposition to the project from multiple landowner groups within the affected area.136
The Mengen FCA is reported to overlap with areas of recognised environmental significance, including the Nakanai Karst
region, which has been included on the Tentative World Heritage List.137
Finally, the report references allegations that police personnel have acted in support of company operations in the area,
including claims that landowners have experienced pressure or suppression of dissent. These matters are presented in the
report as serious governance concerns.138
Prior to publication, Act Now contacted KK Connections Limited for comment on its findings. No response was received.139
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 24
3.2.3 KK Group and Landowner consent
One of the largest logging projects involving KK Connections is the Dengnenge ‘A’ FCA in East New Britain Province.
Between 2018 and 2022, the company is recorded as having exported almost 240,000 cubic metres of logs under FCA
permit 15-10, which was issued in 2016.140 This permit was referred to in the aforementioned Global Witness report,
due the absence of evidence pointing to large-scale agricultural clearance.
FCA permit 15-10 was issued to the landowner company Dengnenge Resources Development Limited.141 Laloani No.8
Limited appear to have then been contracted by Dengnenge to undertake logging operations in the permit area. For 2016
and 2017, PNG export records list Laloani No.8 Limited is listed under the Kerawara corporate grouping, from 2018 it is
listed under the KK Connections corporate grouping.142
However, the permit — FCA 15-10 — was declared invalid and void by the National Court of Papua New Guinea in February
2019. In judicial review proceedings initiated by a group of landowners who stated that they had not consented to the
issuance of the FCA, the Court found that mandatory requirements under the Forestry Act 1991 had not been satisfied prior
to the grant of the licence.143
The Court determined that incorrect forms had been used to verify landowner ownership and consent, and that signatures
on those forms had not been witnessed by an authorised official.
The Court described these deficiencies as “critical” and “crucial,” concluding that the defects rendered the FCA application
made by Dengnenge Resources Development Limited invalid.144 The judgment further stated that overlooking such errors
would “be detrimental to the landowners and their interests over their customary land”.145
These findings reflect concerns similar to those documented during the SABL Commission of Inquiry regarding consent
verification processes implemented by landowner companies looking to facilitate outsourced logging operations.
The Court awarded costs against all defendants in the proceedings, including KK Connections Limited and Laloani
No. 8 Limited.
While the FCA permit was declared void, logging export data indicates logs were exported in 2020, 2021, and 2022,146 under
contracting arrangement with KK Connections Limited and Laloani No.8 Limited.
Ongoing logging conducted under FCA permits declared void by the courts has been identified by the Bank of Papua
New Guinea as an area of elevated money-laundering risk147. This does not mean that logs extracted after FCA 15-10 was
declared void were illegally harvested. However, the factual circumstances indicate that there is a risk that such extraction
may have occurred.
3.2.4 Conclusion
Taken together, the material reviewed in this section indicates that the KK Group has been a significant participant in
Papua New Guinea’s forestry sector, with a substantial proportion of its export activity associated with projects operating
under FCA permits, a licensing pathway that has attracted sustained scrutiny in national inquiries and sectoral reviews.
Evidence considered by the Commission of Inquiry into Special Agriculture and Business Leases (2011–2013), subsequent
civil society reporting, and judicial findings in relation to FCA 15-10 (Dengnenge ‘A’) highlight concerns in some concession
areas regarding landowner consent processes, the adequacy of documentation supporting licence approvals, and the
relationship between authorised agricultural development objectives and observed logging activity.
These issues arise within a forestry governance environment widely recognised as presenting institutional capacity
constraints and implementation challenges. While they do not in themselves establish wrongdoing by the KK Group,
they indicate features of the Group’s operating context that, from an AML and due-diligence perspective, reasonably
warrant closer scrutiny.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 25
4. RISK EXPOSURE OF OUTSIDE ORGANISATIONS
A range of external organisations have been exposed to KK Group forestry operations, which are mapped in this section.
No suggestion is made that these organisations have engaged in any improper conduct. However, organisations with
ongoing commercial relationships with the KK Group are strongly encouraged to take the findings outlined in this report
into account as part of their compliance and risk-review processes, particularly in light of the risk profile documented in
Section Three.
4.1 FINANCE AND PROFESSIONAL SERVICES
Several financial institutions and professional service providers are referenced in documentation relating to KK Group
operations. No suggestion is made that these organisations have engaged in any improper conduct.
For example, the Mengen Project is one of 17 current and past logging operations on New Britain Island associated with
companies within the KK Connections corporate group. In documentation submitted in support of the Forest Clearing
Authority (FCA) application for the Mengen Project, Australia and New Zealand (ANZ) Bank was listed as the “proposed
banker” for KK Connections Limited.148
ANZ notified ACT NOW! in 2023 that it did not have a banking relationship with the companies identified. The bank further
indicated that it has a “limited appetite” for the forestry sector in Papua New Guinea and will generally only consider
customers certified by the Forest Stewardship Council (FSC). ANZ declined to comment on whether it had previously held
banking relationships with KK Connections or related entities.149
The aforementioned FCA application for the Mengen concession also listed Sojitz Corporation, a major Japanese trading
company, as a potential purchaser of timber.150 Sojitz has previously been criticised for purchasing wood originating from
illegal logging concessions in Papua New Guinea. An investigation by Global Witness in 2017 reported that the company
stated it would “not handle wood obtained through illegal logging” and would “seek to mitigate any negative impact”
on human rights.151
Sojitz Corporation was previously a secured creditor of KK Connections Limited. On 10 December 2010, KK Connections
Limited registered a fixed charge in favour of Sojitz Corporation under Section 222 of the Companies Act 1997.152 The charge
secured liabilities arising under a sales contract note, with a maximum prospective liability of US$1,000,000. It was
secured over vehicles and equipment owned by KK Connections Limited and was signed by Han Hook See in the capacity
of Secretary/Director of the company.
Records indicate KK Group companies have also received financing from another non-bank lender Heduru Moni Limited.153
Reported financing includes:
• Asset financing to K L Connections (2019) for seven Toyota Landcruisers;154
• Asset financing to KK Connections (2017–2018) for four Isuzu trucks and twenty-one Toyota Landcruisers.155
The total value of this financing is estimated to exceed K6 million (approximately US $1.6 million).156 When asked by ACT
NOW! and Jubilee Australia, Heduru Moni did not reply to questions regarding these transactions or disclose its policies in
relation to lending to the logging sector.157
In addition to finance, KK Group has received professional services from Jb & Co. a public accountant in Papua New Guinea,158
which specialises in providing secretarial, accounting and audit services.159
Corporate filings also indicate KK Connections has received legal services from Blake Dawson, an international law firm
later acquired by Ashurst.160
No suggestion is being made that these companies are involved in any wrongdoing by providing these services.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 26
4.2 VENTURE PARTNERS
KK Group companies have collaborated with external partners in several reported projects, which will now be briefly
summarised.
4.2.1 Shin Yang Group
The Shin Yang Group is a major Sarawak timber conglomerate which operates under the Ling family.161 There is no evidence
available that Kuok Tiang Ling (Kevin Ling), the founder of KK Connections Ltd, is a member of, or related to, Shin Yang’s
Ling family. The shared surname “Ling” appears in this context to reflect a common family name rather than a documented
familial relationship.
KK Group’s relationship with the Shin Yang Group occurs through Papua New Guinea company KKC Veneer Limited.
The shares in KKC Veneer are held by two entities, PL Jaya Limited (95%) and KKC Sawmill Limited (5%).162 Its board
consists of Dennis Lu Jing Ling, Lu Kiong Ling, and Lu Siong Ling, who are all directors or executives in the Shin Yang
Group. KKC Veneer’s secretary is Dana Foon Ling, who appears to be daughter of Shin Yang’s Group Managing Director.
The primary shareholder of KKC Veneer, PL Jaya Limited is closely tied into the Shin Yang Group. Its shareholders include
Dennis Ling Lu Jing (26.83%), Lu Kiong Ling (26.84%), Lu Siong Ling (26.38%), and Malaysian registered entity, Indah
Asiamas SDN BHD (19.5%).163
Indah Asiamas SDN BHD Malaysian filings indicate it is based at Shin Yang Group’s headquarters, while email contacts are
all Shin Yang Group email addresses. Indah Asiamas SDN BHD is jointly owned by Ling Pau Pau, Derek Ling Lu Yung and
Alfred Ling Lu Khiing, each holding 33.33% of the issued shares.164
The minority shareholder of KKC Veneer is KKC Sawmill Limited, a KK Connections Group entity jointly owned by Kevin
Ling and Han Hook See.165
KKC Veneer Mill, it appears was set up to commission a veneer mill at Kurindal in Lasul-Baining, Gazelle district of East
New Britain Province. When fully operational, the mill is reportedly expected to process approximately 200,000 cubic
metres of logs annually and to produce veneer, wood chips, pellets, and plywood.166
The project was launched in 2023 by Papua New Guinea Prime Minister Marape who noted significant tax exemptions
offered to the joint venture. “The company deserves incentives from my government like export without levy, tax
deductible if you build road, health and school to help people”, the Prime Minister reportedly said.167
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 27
IMAGE: Papua New Guinea Prime Minister on a visit to the KKC Veneer mill in March 2023 Copyright © 2026 PM James Marape
News Page
A field investigation for this report indicates that the mill is no longer operational. According to local sources, the mill shut
down in or around June 2024. It appeared heavy machinery had been removed from the mill site. It was claimed by local
sources, that unanticipated costs had made the project unviable, leading to the site shutdown.
4.2.2. Ningbo Yongli
Corporate records and project documentation indicate that KK Group personnel have had links with a timber company
connected to China-based interests in Ningbo.
Ningbo ND Import and Export Co Ltd is the only shareholder of PNG ND Resources Investment Co which is a PNG registered
holding company.168 PNG ND Resources Investment Co in turns holds 100% of the shares (from at least 2014) in Tian Suyn
Limited, a logging company operating in Papua New Guinea.169
Corporate registry records indicate that Tian Suyn Limited had overlapping directors and shareholders with KK Group
entities predominantly throughout the period 2014 to 2017. Han Hook See and Kuok Tiang Ling were directors and share-
holders of Tian Suyn Limited during this period.170 The board included representatives of PNG ND Resources Investment
Co alongside Ling and See.
Export and forestry records show that between 2010 and 2017, Tian Suyn Limited exported logs from multiple concessions,
including the Suikol-Makolkol Forest Clearing Authority area in East New Britain Province and the Rai Coast Timber Rights
Purchase agreement area in Madang Province.171 The exports appear to have occurred when Tian Suyn Limited had directors
and shareholder from the KK Group, alongside PNG ND Resources Investment Co.172
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 28
5. CONCLUSION
5.1 THE KK GROUP
Section Three of this report has identified a number of circumstances relating to KK Group entities and personnel that may
contribute to an elevated initial risk profile, particularly when considered against wider systemic risk factors affecting the
forestry sector in Papua New Guinea.
First, KK Group entities have historical corporate and personnel links with the Kerawara Group. Judicial findings and
oversight reports have previously associated Kerawara Group operations with illegal logging activity, collusive practices,
and regulatory breaches. Court records further indicate that certain Kerawara officers—including one individual later
reported to have served as a General Manager within the KK Group—were found guilty of criminal contempt of court.
Second, aspects of KK Group logging operations in East New Britain have been identified as raising concern in publicly
available sources. Evidence presented to the Special Agriculture and Business Lease Commission of Inquiry, and in related
judicial proceedings, identified procedural failures in the processes through which landowner consent was obtained for
leases and permits connected to operations involving KK Group entities. While responsibility for these procedural failures
was primarily attributed to government officers and landowner companies, Commissioner Alois Jerewai noted concerns
regarding apparent landowner dependencies on KK Group, in a relationship the Commissioner claimed was marked by
inequalities in sectoral expertise and resources.
In addition, research published by organisations including Global Witness and Act Now! has raised questions regarding
whether certain operations associated with KK Group entities meet the criteria of genuine forest clearance activities as
contemplated under the Forestry Act 1991.
Fourth, one of the largest logging operations associated with KK Connections—the Dengnenge ‘A’ Forest Clearing Authority
(FCA 15-10)—was declared invalid and void by the National Court, after the Court identified critical deficiencies in the
statutory processes used to verify landowner ownership and consent. Notwithstanding this ruling, export records indicate
that substantial volumes of logs were exported under this permit between 2019 and 2022.
Taken together, these cumulative factors support the classification of KK Group as a higher-risk forestry sector participant
within the context of broader systemic risks affecting Papua New Guinea’s forestry governance environment.
Importantly, a higher-risk classification does not imply involvement in unlawful activity. Rather, it indicates that available
information points to features that warrant enhanced scrutiny by regulators, financial institutions, and other gatekeepers
in order to support effective compliance and risk-management processes.
Accordingly, organisations engaged in monitoring forestry sector risks, or interacting with activities linked to KK Group
entities, should consider applying enhanced due-diligence measures proportionate to sectoral risk conditions.
5.2 THE WIDER CONTROL ENVIRONMENT IN PAPUA NEW GUINEA
This Risk Alert also highlights wider structural weaknesses in Papua New Guinea’s control environment. These systemic
issues form part of the context in which the country has been placed on the Financial Action Task Force (FATF) grey list.
Most fundamentally, there are significant limitations in the availability and accessibility of corporate and market data.
Papua New Guinea does not currently maintain a public beneficial ownership register, and existing company filings
contain limited information, much of which is unaudited and only accessible through a paywalled system. In addition,
registry accessibility and data usability declined following system changes introduced in 2022-23, at a time when many
jurisdictions were moving toward greater transparency and digital availability of corporate information.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 29
Given the recognised risks associated with the forestry sector, the absence of a comprehensive public register of forestry
licences and participating entities represents a further constraint on effective due-diligence activity.
As a result, organisations undertaking risk assessments in relation to forestry participants in Papua New Guinea face
significant verification challenges. The specialist resources required to overcome these data gaps are not routinely
available to many private-sector actors. As a result, it is almost certain that risks are systematically going undetected,
allowing illicit financial flows emanating from Papua New Guinea to move out of the country undetected and into global
financial and asset systems.
There is therefore a clear need to strengthen Papua New Guinea’s registry infrastructure and information systems,
including improvements to corporate transparency mechanisms and the publication of a comprehensive public register
of forestry licences and sector participants.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 30
ENDNOTES
1 Financial Action Task Force (FATF), (2021). Money Laundering from Environmental Crime. Paris: FATF.
2 Climate Change and Development Authority (CCDA), (2025). First Biennial Transparency Report to the United Nations Framework
Convention on Climate Change. Port Moresby: CCDA.
3 Bank of Papua New Guinea (2017), Money Laundering and Financing of Terrorism National Risk Assessment, Port Moresby: BPNG, p.93.
See also Bank of Papua New Guinea (2020). Money Laundering and Terrorist Financing Sector Risk Assessment: Forestry Sector - Papua
New Guinea. Port Moresby: BPNG.
4 Forest Trends (2021). Timber Legality Risk Dashboard: Papua New Guinea. Washington, DC: Forest Trends, p.1.
5 FATF (2021). Money Laundering from Environmental Crime, p. 36.
6 Forest Trends (2021). Timber Legality Risk Dashboard: Papua New Guinea, p. 1.
7 Ibid, p. 4.
8 Bank of Papua New Guinea (2020). Money Laundering and Terrorist Financing Sector Risk Assessment: Forestry Sector - Papua New
Guinea. Port Moresby: BPNG, p.24.
9 Forestry Act 1991 (No. 30 of 1991) (Papua New Guinea).
10 This is based on data provided in Société Générale de Surveillance monthly logging reports issued to the Papua New Guinea Forest
Authority.
11 ACT NOW! and Jubilee Australia (2025). The FCA Logging Scandal: A Summary Paper on the Abuse of Forest Clearing Authorities to
Facilitate Large-Scale Tropical Forest Logging in Papua New Guinea. Port Moresby and Sydney: ACT NOW! and Jubilee Australia, p. 10.
12 TUBS, CC BY-SA 3.0 <https://creativecommons.org/licenses/by-sa/3.0>, via Wikimedia Commons
13 ACT NOW! (2023). A new forest grab: The Mengen Integrated Agriculture Project. Port Moresby: ACT NOW!, p. 13; Global Witness (2018).
A major liability: Illegal logging in Papua New Guinea threatens China’s timber sector and global reputation. London: Global Witness, p. 13.
14 ACT NOW! (2023). A new forest grab: The Mengen Integrated Agriculture Project. Port Moresby: ACT NOW!.
15 SGS PNG Ltd (2023). Log Export Monitoring Monthly Report for December 2022 to the Papua New Guinea Forest Authority. Port Moresby:
SGS PNG Ltd, p. 4.
16 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings, Waigani – Commissioner Jerewai
(Part 1, 22 September 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC p. 129.
17 Ibid, p. 130.
18 Ibid, pp. 128, 129.
19 Ibid, pp. 128, 134.
20 Tiden, G. (2013). ‘Bridge Links Provinces’, Post-Courier, 30 May, p. 8.
21 Daiva v Pukali; Ome Ome Forests Ltd v Cheong [2002] PGNC 61; N2289 (8 October 2002)
22 Forest Trends (2006). Logging, Legality and Livelihoods in Papua New Guinea: Synthesis of Official Assessments of the Large-Scale
Logging Industry. Volume I. Washington, DC: Forest Trends.
23 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings, Waigani – Commissioner Jerewai
(Part 1, 22 September 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC, p. 130
24 Maoko v Ling [2008] PGNC 19; N3293 (26 March 2008).
25 Forestry and Conservation Project Review Team (2003). Final Report: Kiunga/Aiambak, Simbali and Bonua Magarida, p.14; Masalai
(2004). Forestry officers conspire with loggers to defraud the State, no. 25, 18 January, pp. 1, 3.
26 Daiva v Pukali; Ome Ome Forests Ltd v Cheong [2002] PGNC 61.
27 Kerawara Limited, Annual Returns, 1998-2006
28 Hugo Sawmilling Limited, Annual Returns, 1998-2006
29 SGS PNG Ltd (2018). Log Export Monitoring Monthly Report for December 2017 to the Papua New Guinea Forest Authority. Port Moresby:
SGS PNG Ltd, p. 5.
30 Commission of Inquiry into Aspects of the Forestry Industry (1989). Final Report, Volume 1, July 1989; Commission of Inquiry into
Aspects of the Forestry Industry (1989). Final Report, Volume 2, July 1989.
31 Filer, C. (2013). ‘Asian investment in the rural industries of Papua New Guinea: What’s new and what’s not?’, Pacific Affairs, 86(2),
pp. 305–325, p. 310
32 Commission of Inquiry into Aspects of the Forestry Industry (1989). Final Report, Volume 1, p. 14; Commission of Inquiry into Aspects
of the Forestry Industry (1989). Final Report, Volume 2, p. 314.
33 Commission of Inquiry into Aspects of the Forestry Industry (1989). Interim Report, No 7, pp.9-14.
34 Ibid, p.12.
35 Ibid.
36 Ibid, p.15.
37 Ibid.
38 Rafflin v Richard Gault Industries Pty Ltd; Kerawara Pty Ltd [1998] PNGLR 394 (3 November 1997).
39 Ibid.
40 Ibid.
41 Ibid.
42 Ibid.
43 Ibid.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 31
44 Ibid.
45 Ibid.
46 Ibid.
47 Ibid.
48 Daiva v Pukali; Ome Ome Forests Ltd v Cheong [2002] PGNC 61; N2289 (8 October 2002)
49 Ibid.
50 Ibid.
51 Ibid.
52 Ibid.
53 Ibid.
54 Ibid.
55 Ibid.
56 Ibid.
57 Ibid.
58 Ibid.
59 Ibid.
60 Ibid.
61 Ibid.
62 Ibid.
63 Department of National Planning and Monitoring (2003). Review of Current Logging Projects Carried Out Under the Auspices of the
Department of National Planning and Monitoring: Finalised Individual Project Review Report No. 1, Timber Permit (TP) 3-27 Iva Inika.
November 2003, p. 1.
64 Ibid, p. 2
65 Ibid, p. 1.
66 Ibid, p. 5.
67 Ibid, p. 9.
68 Ibid, p. 8.
69 Ibid, p. 9.
70 Ibid.
71 Ibid, p. 11.
72 Ibid, p. 12.
73 Ibid, p. 14.
74 Ibid.
75 Forestry and Conservation Project Review Team (2003). Final Report (Kiunga/Aiambak, Simbali and Bonua Magarida). February 2003.
76 Forestry and Conservation Project Review Team (2003). Final Report.
77 Ibid, p.14.
78 Ibid, pp. 8-9.
79 Ibid, p.9.
80 Ibid, p.8.
81 Ibid, p.8.
82 Ibid, p.9.
83 Ibid, p.13.
84 Ibid, pp.13-14.
85 Department of National Planning and Monitoring (2004). Review of Current Logging Projects: Finalised Individual Project Review Report
No. 3 – TP 13-38 Buhem Mongi Busiga. March 2004.
86 Ibid, p. 14.
87 Ibid, p. 2.
88 Ibid, p. 7.
89 Ibid, p. 2.
90 Ibid, p. 13.
91 Ibid, p. 8.
92 Ibid, p. 13.
93 Ibid, p. 14.
94 Ibid, p. 18.
95 This is based on data provided in Société Générale de Surveillance monthly logging reports issued to the Papua New Guinea Forest
Authority and, for 2024, the PNGFA’s own internal monitoring data.
96 The National (2023). ‘Veneer Mill Shines Light on Bainings’. The National. Available at: https://www.thenational.com.pg/veneer-mill-
shines-light-on-bainings/ (accessed 21 January 2026).
97 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings, Waigani – Commissioner Jerewai
(Part 1, 22 September 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC; Forest Trends (2021). Illicit Harvest, Complicit
Goods: The State of Illegal Deforestation for Agriculture. Washington, DC: Forest Trends; Forest Trends (2021). Timber Legality Risk
Dashboard: Papua New Guinea. Washington, DC: Forest Trends.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 32
98 ACT NOW! and Jubilee Australia Research Centre (2025). The FCA Logging Scandal: A Summary Paper on the Abuse of Forest Clearing
Authorities to Facilitate Large-Scale Tropical Forest Logging in Papua New Guinea. Published May 2025, p. 20.
99 This is based on data provided in Société Générale de Surveillance monthly logging reports issued to the Papua New Guinea Forest
Authority and, for 2024, the PNGFA’s own internal monitoring data.
100 Ibid.
101 Ibid.
102 Commission of Inquiry into the Special Agriculture and Business Lease (SABL) (2013). Final Report. Port Moresby, 24 June 2013,
pp. 2, 4, 9, 34, 235.
103 Ibid, pp. 9, 12, 49, 134, 185, 235, 239, 245.
104 Ibid, pp. 15, 42.
105 PNGi Forests, KK Connections (Port Moresby: PNGi Forests, n.d.). Available at: https://pngiforests.org/company/kk-connections
(accessed 12 April 2026).
106 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings, Part 1 (Kokopo: Introductory
Hearings, 24 October 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC, pp. 27, 42, 44.
107 Ibid, p. 43.
108 Greenpeace Australia Pacific (2012). Up for Grabs: Millions of hectares of customary land in PNG stolen for logging. Ultimo, NSW:
Greenpeace Australia Pacific, p.43.
109 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings, Waigani – Commissioner Jerewai
(Part 1, 22 September 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC, p. 135.
110 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings (Kokopo: Substantive Hearings,
9 November 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC.
111 Ibid.
112 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings (Kokopo: Substantive Hearings,
28 October 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC.
113 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings (Kokopo: Substantive Hearings,
12 November 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC.
114 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings (Waigani: Substantive Hearings,
16 November 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC.
115 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings (Kokopo: Substantive Hearings, 9
November 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC.
116 Ibid.
117 Commission of Inquiry into Special Agriculture and Business Leases (2011). Transcript of Proceedings (Kokopo: Substantive Hearings,
9 November 2011). PNGi Portal. Waigani: Department of Prime Minister & NEC.
118 Ibid.
119 Global Witness (2017). Stained Trade: How U.S. Imports of Exotic Flooring from China Risk Driving the Theft of Indigenous Land and
Deforestation in Papua New Guinea. August 2017, p. 41.
120 Global Witness (2017). Stained Trade, p. 41
121 Global Witness (2018). A Major Liability: Illegal Logging in Papua New Guinea Threatens China’s Timber Sector and Global Reputation.
August 2018; Global Witness (2017). Stained Trade; ACT NOW! (2023). A New Forest Grab; ACT NOW! and Jubilee Australia Research
Centre (2025). The FCA Logging Scandal; Forest Trends (2021). Illicit Harvest, Complicit Goods.
122 ACT NOW! (2023). A New Forest Grab, p.6.
123 Forest Trends, Timber Legality Risk Dashboard: Papua New Guinea, p. 6.
124 Global Witness (2018). A Major Liability.
125 Ibid, p. 21.
126 Ibid, pp. 14, 15.
127 Ibid, p. 14.
128 SGS PNG Ltd (2018). Log Export Monitoring Monthly Report for December 2017 to the Papua New Guinea Forest Authority. Port Moresby:
SGS PNG Ltd, Report 11, p. 6
129 Global Witness (2018). A Major Liability, p. 15.
130 Ibid, p. 31.
131 Ibid.
132 ACT NOW! (2023). A New Forest Grab.
133 Ibid, pp. 5,10.
134 Ibid, p. 5.
135 Ibid.
136 Ibid, p. 13.
137 Ibid, p. 5.
138 Ibid.
139 Ibid, p. 17.
140 Ibid.
141 Ibid, p. 6.
142 PNGi Forests, Dengnenge ‘A’ Int. Agric Project (FCA 15-10) (Port Moresby: PNGi Forests, n.d.). Available at: https://pngiforests.org/
licence/dengnenge-a-int-agric-project (accessed 12 April 2026)
143 Simakade Holdings Ltd v National Forest Board [2019] PGNC 18; N7703 (22 February 2019).
144 SGS PNG Ltd (2017) (2018) (2019) (2020) (2021) (2022) (2023). Log Export Monitoring Monthly Report for December to the Papua New
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 33
Guinea Forest Authority. Port Moresby: SGS PNG Ltd.
145 Ibid.
146 Ibid.
147 Ibid.
148 PNGi Forests, Dengnenge ‘A’ Int. Agric Project (FCA 15-10) (Port Moresby: PNGi Forests, n.d.). Available at: https://pngiforests.org/
licence/dengnenge-a-int-agric-project (accessed 12 April 2026).
149 Bank of Papua New Guinea (2020). Money Laundering and Terrorist Financing Sector Risk Assessment: Forestry Sector - Papua New
Guinea. Port Moresby: BPNG, p.23.
150 ACT NOW! (2023). A New Forest Grab, p. 21.
151 Ibid.
152 Ibid, p. 23.
153 Ibid.
154 KK Connections Limited, Fixed Charge in favour of Sojitz Corporation, Form 24 annexure (certified copy), dated 10 December 2010,
lodged under Companies Regulation 1998 (Papua New Guinea), PNG Investment Promotion Authority (Companies Office records).
155 ACT NOW! and Jubilee Australia Research Centre (2023). Lending to the Loggers: How the Non-Bank Sector Is Financing Forest
Destruction in Papua New Guinea. May 2023.
156 Ibid, p.19.
157 Ibid, pp. 19, 20, 21.
158 Ibid, p. 10.
159 Ibid, p. 5.
160 KK Connections Limited, Annual Return (Form AR-1), dated 30 June 2025, PNG Investment Promotion Authority (Companies Office
records), Company No. 1-53019 (Papua New Guinea).
161 JB & Co Accountants, Home (Port Moresby: JB & Co Accountants, n.d.). Available at: https://jbco.com.pg/ (accessed 13 April 2026).
162 KK Connections Limited, Fixed Charge in favour of Sojitz Corporation, Form 24 annexure (certified copy), dated 10 December 2010,
lodged under Companies Regulation 1998 (Papua New Guinea), PNG Investment Promotion Authority (Companies Office records).
163 Shin Yang Group Berhad, Annual Report, 2025.
164 KKC Veneer Limited, Annual Return, 2024.
165 PL Jaya Limited, Certificate of Good Standing - Long Form, 15 February 2023.
166 Indah Asiamas SDN. BHD., Corporate Information, 23 May 2024.
167 KKC Sawmill Limited, Certificate of Good Standing - Long Form, 13 March 2023.
168 The National (2023). ‘Veneer Mill Shines Light on Bainings’.
169 EMTV Online (2023). ‘KKC Veneer Mill Focus on Downstream Processing’, 11 March. Available at: https://emtv.com.pg/kkc-veneer-mill-
focus-on-downstream-processing/ (accessed 13 April 2026).
170 PNG ND Resources Co. Limited, Certificate of Good Standing - Long Form, 15 May 2023.
171 Tian Suyn Limited, Certified Historical Extract, 10 July 2025.
172 Ibid.
KEVIN LING, THE KK CONNECTIONS CORPORATE GROUP AND ITS LOGGING OPERATIONS IN PAPUA NEW GUINEA 34
actnowpng.org
