NATIONAL ECONOMICS UNIVERSITY

SCHOOL OF ACCOUNTING AND AUDITING

FINANCIAL ACCOUNTING 3

TOPIC: ANALYSIS OF THE ACCOUTING FRAUD FOR REVENUE OF

LUCKIN COFFEE

Class : Auditing Integrated with ICAEW CFAB

Intake : 62

Tutor : Ph.D. Dang Thi Thuy Hang

Group members : Nguyen Viet Anh - 11204468

La Ngoc Mai Anh - 11200126

Nguyen Thao Hien - 11201421

Hoang Thanh Huyen - 11205518

Dang Hoang Ngan- 11202731

Hanoi, 2023

TABLE OF CONTENT
I. INTRODUCTION.................................................................................................1

1.1. Overview of IFRS 15.......................................................................................1

1.2. Overview of Luckin Coffee.............................................................................1

II. ANALYSIS OF THE ACCOUNTING FRAUD FOR REVENUE OF

LUCKIN COFFEE........................................................................................................4

2.1. Case Description..............................................................................................4

2.2. Case Analysis....................................................................................................7

2.2.1. First Fraudulent Scheme.......................................................................7

2.2.2. Second Fraudulent Scheme...................................................................7

2.2.3. Third Fraudulent Scheme.....................................................................7

2.3. Case Assessment.............................................................................................10

2.3.1. Case Assessment of Luckin Coffee’s Financial Accounting on

Revenue Based on IFRS 15.................................................................................10

2.3.2. The Consequences of the Fraud.........................................................11

2.4. Solutions..........................................................................................................13

2.4.1. For Company.......................................................................................13

2.4.2. For Auditors.........................................................................................13

2.4.3. For Investors........................................................................................13

2.4.4. For Government Authorities..............................................................14

2.4.5. For Company Management................................................................15

III. CONCLUSION..................................................................................................16

REFERENCES............................................................................................................17
 LIST OF FIGURES

Figure 1. The number of stores growing at an unprecedented rate of Luckin…………………

3

Figure 2.1. Luckin Coffee's stock price since its first

release………………………………….4

Figure 2.2. Report the number of items per store, per day…………………………………….5

Figure 2.3. Results of monitoring the Luckin Coffee store system in the fourth quarter of
2019…………………………………………………………………………………………….6

Figure 2.4. Market share of coffee sales in China as announced by Luckin…………………..6

Figure 3.1. An Example of Fabricated Expenses and Returned

Funds………………………...9

Figure 3.2. Stock of Luckin………………………………………………………...…………

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 LIST OF ABBREVIATIONS

1. CEO: Chief Executive Officer

2. Co.: Company
3. COO: Chief Operating Officer
4. IAS: International Accounting Standards
5. IFRS: International Financial Reporting Standards
6. IPO: Initial Public Offering
7. LLC: Limited Liability Company
8. Ltd.: Limited
9. NASDAQ: National Association of Securities Dealers Automated Quotation
10. SEC: Securities and Exchange Commission
11. U.S.: United States

12. WSJ: Wall Street Journal

I. INTRODUCTION
I.1. Overview of IFRS 15

IFRS 15, also known as "Revenue from Contracts with Customers," is a new accounting
standard that provides a comprehensive framework for how entities should account for
revenue derived from customer contracts. It replaces existing revenue recognition guidelines
such as IAS 18 and IAS 11, along with related Interpretations. The primary objective of IFRS
15 is to ensure that entities report relevant information in financial statements concerning the
nature, amount, timing, and uncertainty of revenue and cash flows generated from customer
contracts. The core principle of IFRS 15 is to recognize revenue in a manner that represents
the transfer of promised goods or services to customers, reflecting the expected consideration
in exchange for these goods or services. This principle is implemented through a five-step
model:

(1) Identifying the contract(s) with a customer.

(2) Identifying the performance obligations within the contract.

(3) Determining the transaction price.

(4) Allocating the transaction price to the performance obligations.

(5) Recognizing revenue when (or as) the entity fulfills a performance obligation.

IFRS 15 also introduces an expanded set of disclosure requirements related to revenue

recognition. The standard became effective for annual periods starting on or after January 1,
2018, with the option for earlier adoption.

I.2. Overview of Luckin Coffee

Luckin Coffee, an LLC, was established in October 2017. After six months of testing
and product development, the company officially launched its products, processes, and
systems in May 2018 with 535 stores. The company is headquartered in Hefei, Anhui
Province, China.

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 Luckin Coffee's brand vision is "To make great coffee highly accessible to all
customers,” and its brand mission is "To create a world-class coffee brand with Chinese
roots." By leveraging mobile technology, an Internet retailing model, and big data, the
company deeply collaborates with leading suppliers in various fields, committed to providing
customers with high-quality, cost-effective, and convenient products.

Luckin Coffee confidently believed it had a business model that could outperform
Starbucks as one of the most popular coffee chains in China. Their strategy was to open a
series of smaller stores and surpass Starbucks in terms of the number of outlets by the end of
2019. According to them, to beat Starbucks, Luckin was willing to spend $130 million
annually. The company implemented a fast delivery app that promised delivery in as little as
18 minutes, along with many promotional programs. Specifically, Luckin provided two ways
for customers to make purchases:

(1) Through a third-party-operated digital payment platform, such as WeChat Pay or

Alipay.

(2) By redeeming vouchers through Luckin's app. Customers could pre-purchase these
discount vouchers through Luckin's app. According to Luckin, revenue from the sale of
discount vouchers was calculated based on repeat purchases rather than the actual number of
vouchers sold.

In May 2019, Luckin Coffee went public on the NASDAQ stock exchange, raising $651
million through its U.S. IPO, which valued the company at around $5 billion in its first
trading session. The company's valuation doubled to $12 billion just eight months after going
public, satisfying many large investors in the United States, according to The Wall Street
Journal (WSJ).

Around April 2020, the U.S. SEC, the China Securities Regulatory Commission, and
China's State Administration for Market Regulation initiated an investigation into Luckin's
activities. The U.S. SEC found that Luckin's actions constituted fraudulent behavior.

The company was delisted from the NASDAQ on June 29, 2020. In December 2020,
Luckin Coffee, the Chinese-based coffee retailer, agreed to pay $180 million to settle
allegations of fraud and accounting misconduct.

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Figure 1. The number of stores growing at an unprecedented rate of Luckin.

Source: AlphaStreet

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II. ANALYSIS OF THE ACCOUNTING FRAUD FOR REVENUE OF LUCKIN
COFFEE
II.1. Case Description

Luckin Coffee engaged in fraudulent financial reporting practices by deliberately

manipulating its financial statements.

The company, which was listed on the stock market, adjusted its financial reports in a
manner that can be described as "window dressing." These manipulations involved intentional
misapplication of accounting principles, embellishing business results, altering the balance
sheet, and omitting significant information in the financial statements.

In the first quarter of 2019, Luckin reported revenue of $71.3 million, which exceeded
half of its total revenue for the entire year of 2018. Luckin marked a rapid growth in the first
quarter of 2019, with its estimated market value increasing from $1 billion in July 2018 to
$3.9 billion by May 2019. Public reports regarding Luckin's swift expansion even pushed the
company's valuation to $5 billion at one point. There was a time when Luckin's stock price
reached a peak of $50.

Figure 2.1. Luckin Coffee's stock price since its first release.

Source: FactSet, Data as of market open on 4/2/2020

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 Muddy Waters is an American-based investment research firm specializing in the
investigation of financial fraud. In January 2020, Muddy Waters Research received an
anonymous report along with supporting evidence, alleging fraudulent activities by Luckin
Coffee. Muddy Waters publicly disclosed this report on its Twitter account.

The report asserted that Luckin had artificially inflated its performance by inflating
sales figures, selling discount vouchers, and repurchasing its own shares. An independent
investment firm seemingly discovered this by deploying 1,500 individuals to sit in Luckin's
outlets and observe transactions, revealing that there were significantly fewer customers in the
stores than Luckin had reported. This methodology represents one of the audit forensic
techniques - the techniques of observation, calculation, and analysis.

The report raised questions about Luckin's operations and revealed a substantial volume
of fraudulent sales. It indicated that Luckin had marked an increase in consumption by 69% in
the third quarter of 2019 and 88% in the fourth quarter of the same year.

Figure 2.2. Report the number of items per store, per day.

Source: Luckin, Earnings Release Presentation, Quarter 3/2019

Meanwhile, the company's tracking results in the fourth quarter of 2019 showed only
263 items per store, per day.

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 Figure 2.3. Results of monitoring the Luckin Coffee store system in the fourth quarter of
2019.

Source: Luckin filings, offline footage tracking

Furthermore, the report raised questions about the significantly high revenue figures,
inaccurate accounting practices, and the abuse of managerial authority. It also queried the
unusually high coffee sales ratio in China claimed by Luckin, as a substantial portion of
caffeine consumption in China comes from tea rather than coffee.

Figure 2.4. Market share of coffee sales in China as announced by Luckin.

Source: Luckin Coffee

The report reveals that Luckin utilized the sale of discount vouchers to inflate its
revenue. Starting from early April 2019, with the involvement of employees in three forms of
fraudulent activity, transactions were conducted by generating discount vouchers for three
categories of consumers: retail customers, business clients, and sales to third-party companies.
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Some intermediaries resold these vouchers to retail customers. Some of Luckin's managers
and employees were, in fact, aware of this scheme and were involved in erroneous accounting
practices.

II.2. Case Analysis

II.2.1. First Fraudulent Scheme

In April 2019, just one month before its IPO, Luckin began fabricating the number of
discount vouchers sold and redeemed by individual customers. A group of Luckin employees
initiated this deceptive practice by using personal accounts to purchase a large number of
discount vouchers on Luckin's app. They would then repurchase these vouchers and create
fake orders, deliberately and dishonestly inflating sales figures. This action helped Luckin
falsify revenue by approximately over $1 million.

II.2.2. Second Fraudulent Scheme

Subsequently, the fraudulent activities became even more complex. By the end of May
2019, orders began to surge due to a series of coffee voucher sales to numerous corporate
customers. Alongside selling coffee vouchers to legitimate customers like airlines and banks,
data showed that numerous transactions by Luckin were carried out with a multitude of
anonymous companies across China. These companies consistently purchased large quantities
of coffee vouchers from Luckin, and sometimes they placed orders at night.

For instance, Qingdao Zhixuan Business Consulting Co. Ltd., located in Guangdong
Province, once purchased Luckin's coffee vouchers with a total value of 960,000 Chinese
yuan (approximately $134,000) in a single order. This company also placed a hundred similar
orders between May and November 2019.

This activity generated over $10 million in revenue for Luckin from corporate
customers.

II.2.3. Third Fraudulent Scheme

Luckin employees were involved in creating counterfeit discount vouchers sold to third-
party companies. These shell companies would then resell these vouchers to individual
customers, who were possibly also employees, as they didn't place real orders or redeem the

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vouchers. Some Luckin employees or affiliated individuals established and controlled these
shell companies, which transferred money to Luckin. Subsequently, the employees would
change the sender's name from the capital-providing company to the shell company on
Luckin's bank reconciliation statement. This counterfeit voucher scheme constituted a
significant portion of the fabricated revenue, accounting for approximately 90% of the total
$113 million.

Additionally, some Luckin employees transferred data from the actual business
operation database to the fabricated database. This data included transactions necessary for
financial reporting and accounting entries. Luckin's finance department could only access the
fabricated database, making it impossible for them to detect any irregular transactions.

Apart from recording revenue from fake business orders, Luckin also made payments to
dozens of third-party companies through bank transfers and fictitious expenses. These were
presented in the financial statements as business-related costs, payments to suppliers, etc.
However, many of these input material suppliers, transportation, and human resource service
providers didn't offer any actual services or products to Luckin. In fact, many of these
"suppliers" didn't even exist by April and May 2019. Therefore, Luckin also falsified costs to
match the exaggerated revenue.

According to sources close to Luckin, Chinese authorities recently scrutinized Luckin's

system and uncovered a series of suspicious payments totaling over 1 billion Chinese yuan
(approximately $140 million). Documents indicate that these payments were made by an
employee named Liang, who was found not to exist, as per the sources. The WSJ cited
internal documents and a source close to the matter, claiming that Luckin's CEO, Jenny Qian,
was the one behind these payments, and in some cases, she even supervised the payment
process.

Registration records of the coffee voucher-purchasing businesses and the "suppliers"

indicate a direct connection to Luckin, Chairman Lu, or Lu's two previous companies. Some
companies share addresses and contact information with branches of CAR Inc. or Ucar, two
startups founded by Lu. Others have the same email addresses as employees of these
companies. A few other companies have connections to Lu's relatives or acquaintances. For
instance, Date Yingfei (Beijing) Data Technology Development Co. Ltd., a company
frequently buying Luckin's coffee vouchers, shares a phone number with a CAR Inc. branch.

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Meanwhile, Zhengzhe International Trade (Xiamen) Co., which appears on the books as a raw
material supplier for Luckin, shares a legal representative - Wang Baiyin, a former
schoolmate of Lu - who owns 60% of Date and 95% of Zhengzhe.

Figure 3.1. An Example of Fabricated Expenses and Returned Funds.

Source: The Wall Street Journal

Earnings in the second quarter of 2019: Luckin substantially overstated its revenue
by 27%, expenses by 9%, and net loss was understated by 15%

Earnings in the third quarter of 2019: Luckin’s revenue and expenses were
overstated by 45% and 24%, respectively, and its net loss was understated by 34%. Further,
Luckin’s share price increased 60% from the IPO price.

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 Fabricated sales and expenses in the fourth quarter of 2019: Luckin continuously
fabricated coupon sales, and overstated revenue and expenses. Luckin’s share price increased
100% from the IPO price

Equity offering and bond issuance in January 2020: Luckin obtained an equity
offering and convertible bond offering of about USD 418 million and USD 446.7 million,
respectively. These offerings were based on the fabricated financial performance as
mentioned above. Within eight months of Luckin’s IPO listing, the company’s stock price
increased 200%

II.3. Case Assessment

II.3.1. Case Assessment of Luckin Coffee’s Financial Accounting on Revenue Based on
IFRS 15

 Violation of IFRS 15 Principles:

Premature Revenue Recognition: The heart of the accounting fraud was the premature
recognition of revenue. Luckin Coffee recognized revenue from fictitious sales transactions
that did not meet the criteria set out in IFRS 15. The standard requires that revenue be
recognized when control of the goods or services is transferred to the customer, and this key
principle was disregarded.

 Material Misstatement of Revenue:

Magnitude of the Misstatement: The financial revenue fraud involved a material

misstatement of the company's financial statements. The company significantly overstated its
revenue figures by creating fake sales transactions and inflating the number of products sold.
This had a substantial impact on Luckin Coffee's financial position and misled investors.

 Ethical Lapses and Corporate Governance:

Unethical Conduct: The case highlights significant ethical lapses within the company,
including the fabrication of sales figures to create a false impression of financial strength.

Weak Corporate Governance: The case also raises questions about corporate
governance practices at the company, as such a large-scale financial fraud typically requires
the complicity of top executives.
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II.3.2. The Consequences of the Fraud

The U.S. SEC, the regulatory authority for securities in China, and the State
Administration for Market Regulation of China have initiated an investigation into Luckin's
conduct. The U.S. SEC has found that Luckin's wrongdoing constitutes fraudulent behavior.

Figure 3.2. Stock of Luckin.

Source: vietstock.com

 On April 2, 2020, Luckin's stock plummeted by 81%. Trading of Luckin's stock was
initially suspended but resumed on May 20, 2020.
 Luckin conducted an internal investigation, and in April 2020, it announced that over
300 million USD had been fabricated in 2019, and related financial reports would be
restated. Twelve employees working with the CEO and COO involved in various
forms of fraud were terminated.
 In July 2020, Luckin's CEO, Jenny Zhiya Qian, was fired. Furthermore, evidence
indicated that companies purchasing redemption shares were connected to the
chairman. The chairman was removed from office in July 2020.

The SEC accused Luckin of fabricating false reports from April 2019 to January 2020
regarding revenue, expenses, and net losses to deceive investors about Luckin's financial

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performance. The SEC concluded its investigation and announced penalties against Luckin on
December 16, 2020. This led to Luckin agreeing to a settlement, including a permanent ban
and a 180 million USD fine. Luckin did not admit or deny the allegations.

Ultimately, Luckin's rapid growth was as swift as its downfall. Instead of steady and
cautious growth, Luckin chased numbers and inflated its profit potential blindly. However,
poor cost management and significantly lower actual sales figures compared to the reported
numbers led Luckin to the brink.

 The financial accounting fraud at Luckin Coffee, which involved violations of IFRS 15,
had significant consequences for the company, its stakeholders, and the broader financial
market. Here are the key consequences:

First and foremost, investors in Luckin Coffee, including those who participated in its
IPO and traded its shares on the stock market, suffered substantial financial losses. As a result
of the overstatement of revenue, the company's stock price plummeted, causing significant
financial harm to shareholders.

Secondly, the case also eroded trust in the financial reporting of Chinese companies
listed in the U.S. Luckin Coffee's fraud raised concerns about the auditing and oversight of
Chinese firms and the reliability of their financial statements. This loss of trust can impact not
only the company in question but also the broader market.

Furthermore, the case highlighted the potential risks associated with investing in
Chinese companies listed on U.S. stock exchanges. As a result, there were discussions about
regulatory changes and enhanced oversight of these companies to ensure transparency and
reliability.

Besides, the financial accounting fraud at Luckin Coffee raised questions about the
effectiveness of corporate governance practices within the company. It demonstrated how
weak controls and ethical lapses at the executive level can lead to significant financial
misstatements.

Additionally, the case also affected the reputation of the coffee retail industry in China,
highlighting the potential pitfalls of rapid expansion and competitive pressures in the sector.

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 Lastly, the case put a spotlight on the role of auditors and raised questions about their
due diligence and effectiveness in detecting fraud. This may lead to increased scrutiny of
auditing practices in the future.

II.4. Solutions

Through the scandal of Luckin Coffee and other classical scandals of the past decades,
it can be recognized that errors in financial reporting, and fraud in particular, have developed
alongside the evolution of society and have become increasingly sophisticated, making them
ineradicable behaviors. Fraud has a negative impact on the development of society. In
Vietnam, as well as in other countries worldwide, the risk of financial reporting fraud by
companies is very high. Therefore, measures are needed to address this issue.

II.4.1. For Company

To limit and detect fraud, it is essential to establish an effective internal control system.
Vietnamese businesses need to have a proper awareness of the importance and benefits of
building a strong internal control system. In addition, to detect fraud, companies can use
various methods such as establishing an internal audit department or setting up a hotline to
quickly collect information.

II.4.2. For Auditors

Ultimately, one of the main goals of financial statement audits is to contribute to the
stability of the securities market by confirming whether the financial statements are accurate
and reasonable. If this goal is not achieved, the existence of the auditing profession will no
longer be necessary. Auditors can use research models to support audit planning to save costs.
Audit software programs can also help identify trends related to financial ratios and provide
suitable audit procedures to enhance audit efficiency.

II.4.3. For Investors

From an investor's perspective, it's important to be highly critical when examining

companies. To minimize risks, investors also need to have a good understanding of
economics, finance, and accounting. Company reports should be monitored over multiple
periods to see the real health of a company. It's important to remember that those who

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compile financial statements have the most interest in making themselves look as good as
possible.

Here are some things to keep in mind when making investment decisions:

 Perspective: Does what the company says make sense when compared to other
companies in their industry?
 Trustworthiness: Can you trust the people leading the company? Do they have a
track record of reliability?
 Reasoning: Do their growth projections seem realistic, or are they wearing rose-
colored glasses? In Luckin's case, they projected opening significantly more stores in
2 years than Starbucks had in 2 decades.

With independent investors, some may not have the time or resources to gain in-depth
insights into companies like Luckin Coffee. On the surface, it may seem like a great
investment at the time. However, with an insider's perspective, there may be some red flags.
Therefore, seeking advice from an industry expert can help save a lot of time and, most
importantly, money.

II.4.4. For Government Authorities

The government should strengthen penalties for financial reporting fraud. The Ministry
of Finance has already considered all possible violations in the preparation of financial
statements that may occur in practice and has specified specific fine levels, but the level of
strictness is not high. The Ministry of Finance plans to submit to the Government a proposal
to increase the maximum penalty for administrative violations in the accounting field to 30
million VND. "This penalty is not low, but it is not severe if it does not prosecute before the
law for fraudulent activities to gain benefits, causing serious damage to investors,"
commented Dang Van Thanh, Chairman of the Vietnam Association of Accountants and
Auditors.

Vietnam's economy is in a period of inflation and macroeconomic variables are

constantly changing, so setting a limit is not appropriate. It's recommended to change the
administrative fine policy as follows:

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  For administrative fines, specify the penalty based on the proportion of the amount
causing harm instead of setting a specific limit.
 In cases of individuals or organizations deliberately distorting financial statements,
causing serious damage, such as manipulation, there should be criminal prosecution.

II.4.5. For Company Management

Truthful and reasonable financial reporting is the responsibility of the company's board
of management. Therefore, company management needs to be responsible for preventing and
limiting fraud in financial reporting. Based on the research results, company management can
allocate more resources to control management through the identification of fraud indicators.
This will ensure that the company's operations comply with the law, accounting transactions
are recorded and processed in accordance with accounting policies and standards, accounting
estimates are used properly and reasonably, the company's assets are secured, and the interests
of investors and creditors are protected, attracting the confidence of investors, and ensuring
that all financial statements are free of material errors or fraud.

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III. CONCLUSION

There are several elements that contributed to the notorious scandal of Luckin Coffee.
Not only did the company violate IFRS 15 Principle of Premature Revenue Recognition, it
also considerably overstated its revenue figures. Moreover, the case highlights significant
ethical lapses and raises questions about corporate governance.

Luckin should have established and applied a stronger ethical rule throughout the
company, from top management to frontline employees, to detect fraud earlier and maintain
consistency with the principles of fair exchange. External auditors need to be more proactive
in identifying red flags about the company’s misconduct, as well as avoiding ensuring
financial operations for other parties until the company has been audited. Regulatory agencies
also play a role in preventing illegitimate transactions by implementing and enforcing laws.
There is supervision, investigation, and ethical obligations between regulatory agencies and
publicly listed companies. Regulatory agencies in China and the United States should ensure
that Luckin fulfills its obligation to integrity and transparency before listing. A more
comprehensive and rigorous system may have brought Luckin’s fraud to light earlier.

In the future, structural changes may reduce the risk of fraud. First, strengthening the
enforcement powers of regulatory agencies can promote the investigation process and
minimize the negative impact of fraudulent behavior. Second, providing more training
courses on detecting fraud for auditors will enhance their skills and ability to detect
inappropriate transactions. Third, enhancing the transparency and effectiveness of the internal
audit system will help auditors make balanced judgments from all aspects.

It is hoped that Luckin’s case will raise awareness of the importance of multi-level
cooperation for financial ethics and ethical culture of a company.

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