But among the most damaging revelations in the 83-page KPMG report is that $30 million was transferred from the trust account of Landerer & Company, run by prominent Sydney lawyer John Landerer.
Mr Kelly said this money was used “potentially to repay another investor”.
The report said the $30 million was transferred to a Singapore entity and “appears to be a redemption of investor funds” and was categorised in the trust account ledger as “return of subscription money”.
“The company appears to have used funds raised from investors and deemed to be held on trust in a manner which was inappropriate and in breach of certain agreements between investors and the company,” the report said.
A trust account can only transfer money based on client instructions.
A Ponzi scheme is defined as using funds from one investor to repay another.
Mr Landerer’s law firm had been named as a defendant in a legal action brought by Singaporean investor ZACD, which lost around $37 million from the collapse of iProsperity Capital Management.
Mr Landerer was often referred to as the chairman of iProsperity in newspaper articles and on the company’s website, but he told The Australian Financial Review he never held such a position.
“I agreed to be chairman and then two days later the offer was withdrawn,” Mr Landerer said last month.
Despite this he posed for a photo with his arm around Mr Gu and appeared in a video, as chairman, wishing investors a happy Chinese New Year in 2018.
The report does not allege that Landerer was part of the management of the group of companies.
Filings with the corporate regulator show he never held a statutory role with the company. KMPG said he may have held the role of chairman, along with being a legal adviser to the company.
The administrator said Mr Gu had not attended an initial interview with KMPG or provided any reasons for the company’s failure.
Mr Kelly also said the company had failed to maintain any financial or management accounts.
This is despite iProsperity Capital Management raising $60.5 million to buy a portfolio of IBIS Hotels across Australia in a deal worth around $220 million.
The administrator said the entire $60.5 million raised from investors was missing and the broader group appears to have no assets.
The Singaporean firm, ZACD, invested in this deal along with high net worth individuals believed to be part of the federal government’s Significant Investor Visa Program.
The KPMG report said $14.1 million in investor funds had been paid to Mr Gu personally and a further $11.7 million to related parties.
Along with the $30 million transferred from the Landerer trust account, there was a further $500,000 payment to Mr Landerer’s law firm and $4.3 million was paid to investors and others.
The report said $290,000 was used to partially fund the purchase of a Lamborghini Urus on May 13.
It was sold back to the dealer just over two months later and is currently for sale at Ferrari Maserati Sydney.
“Ferrari Maserati confirmed that the purchase price was $360,000 of which $207,408 was remitted to the Director and the balance to the finance company,” the report said.