Chinese Name: 白沙，白沙二期
Location: Ochheuteal Beach, Sangkat Buon, Sihanoukville, Preah Sihanouk Province & National Road 4, Sangkat Bei, Sihanoukville, Preah Sihanouk Province, Cambodia.
- Ahr San
- Wang Qiang (王強)
- Yu Lingxiong (俞凌雄) / Pov Chumnit (ពៅ ជំនិត)
- White Sand Group (白沙集团)
- White Sand Real Estate Co., Ltd.
- David and White Sand Palace Co., Ltd.
- White Sand Palace Property Management Co., Ltd.
- White Sand Land Development Co., Ltd.
- Bright Beach International Co., Ltd.
- Bright Beach International Group Co., Ltd.
- Bright Beach Property Co., Ltd.
- Bright Beach Entertainment Co., Ltd.
- Zhongxing International Holding Group (众兴国际控股集团)
- K99 Group
What Do We Know about White Sand?
White Sand, or ‘Baisha’ (白沙) in Chinese, is a business group that owns the White Sand Palace Hotel (白沙皇宫酒店) as well as a compound known as White Sand 2. White Sand Palace also houses the White Sand Palace Casino (白沙皇宫娱乐城). This is open to the public, but testimony from people who escaped the building indicate that upper levels of the hotel were separated and used to house scam operations. White Sand Palace is located in the Ochheuteal Beach area of Sihanoukville and the White Sand 2 compound on National Road 4 in the north of the city.
White Sand 2 is also marked on Google Maps as ‘新城国际娱乐城’ (Xincheng International Entertainment City). Media reports from 2018 covered the ground-breaking of the ‘Xincheng International Project’, a US$180-million office complex. The design for the complex matches the layout of what is now White Sand 2, although the actual development is much more basic and incomplete as of 2022.
In 2019, the China Youth Daily (中国青年报), the newspaper of the Communist Youth League of China, ran an article on the phenomenon of ‘pig butchering’ (杀猪盘), scams through which operators groom victims and trick them into investing in fake products or gambling on rigged games. It told the story of one gang that operated from the Xincheng International building. In April 2019, after Cambodian law enforcement and police from Chongqing established a joint task force to investigate scams being run from the compound, they found evidence of scams targeting tens of thousands in China, across multiple provinces, and valued at over RMB 100 million.
White Sand has featured in numerous reports linked to online scams and imprisonment of workers. Reports from early 2022 by China’s Beijing Youth Daily (北京青年报) and Southern Weekly (南方周末) both identified White Sand as a site of online crime. Beijing Youth Daily, the newspaper of Beijing’s Communist Youth League, reported on the case of one man who said he was kidnapped and sold to White Sand 2 (白沙二期) for US$12,800, before being sold again to Kaibo for US$21,000 (see Kaibo profile here). At White Sand, he was required to work on ‘pig butchering’ scams. When he refused to work, he was handcuffed to an iron bed in a small dark room for three days and given only one bowl of instant noodles to eat for the whole duration, after which he was sold to Kaibo. Both articles have since been deleted, but the Beijing Youth Daily article is accessible here and the Southern Weekly article can be found via Wayback Machine.
A documentary by Al Jazeera released in July 2022 included an interview with a 16-year-old girl who claimed she was sold to White Sand Palace in August 2021. She said that upper levels of the hotel were closed off and occupied by scam operations. According to her story, she was both a victim of violence and sexual harassment, and witnessed beating of other workers while being forced to do online sex scams. After three months, she attempted suicide and while recovering in hospital was rescued by a Chinese volunteer group. Al Jazeera also spoke with a man who was brought to White Sand 2 in May 2021. He was told that he had to work for six months or pay US$6,000 to leave. He was required to work 15-hour days on a cryptocurrency-based romance scam targeting wealthy Chinese women living overseas.
In September 2022, ProPublica published an in-depth report on the online scam industry, speaking with several survivors. This included one 22-year-old man who ended up in a scamming compound in 2021 after responding to a job in marketing with a delivery company in Cambodia. The job turned out to be fake and, along with his brother, he eventually found himself in White Sand Palace. A few weeks after arriving there, they were sold to another scam compound, Triumph City (see profile here).
It is not only Chinese nationals that have been held at White Sand. In 2021, Thomson Reuters published an article on foreign workers and tourists stranded in Cambodia due to the Covid-19 pandemic being trafficked and forced into work in ‘Chinese-run online scams’. One expat from Nepal who was laid off from his job during the pandemic responded to a Facebook advert for a call centre job but ended up in White Sand Palace. While there, he was told to operate a QR code scam. According to his testimony: ‘To them, we are just animals; bought and sold like goats and chickens … People go in [to the hotel] … then they cannot go out.’ He was released after he told the company that his wife would report the operation to the police.
There have been a number of violent events in and around White Sand over the past few years. In July 2018, media reported that over 50 Chinese men ran into White Sand Palace chasing people with knives, in what Cambodia-China Times compared to ‘a Hong Kong gangster blockbuster’. The attackers fled when police arrived, leaving one person seriously injured and five in custody. In May 2019, a Chinese man was arrested for attempted murder after stabbing a compatriot at a hotel in Sihanoukville. The hotel was not named, but it was in the same village as White Sand Palace, which was reported to be the residence of the suspect. The same month a man was shot in the head after getting in a car outside White Sand Palace and his body was dumped in the road, in an incident captured on video and widely circulated at the time. In August 2021, Sihanoukville police arrested four Chinese nationals who attempted to kidnap another Chinese citizen. Media reports described one of the alleged kidnappers as a manager at White Sand Palace.
With this activity ongoing, the company continued to maintain a good relationship with Cambodian state and elite actors. At the company’s 2021 Chinese New Year event, Preah Sihanouk Provincial Governor Kuoch Chamroeun and commander of Prime Minister Hun Sen’s Bodyguard Unit Hing Bun Hieng were in attendance and gave speeches. Hing Bun Hieng has had numerous interactions with White Sand executives, this is returned to below.
In January 2020, workers from White Sands Palace Casino (which continued to operate a public facing in-person casino) went on strike, protesting the suspension of a 13th-month payment allowance. White Sand Group issued a statement in response saying that since its opening it did not owe ‘a single penny’ of wages to employees. The company claimed it had optimised salary structures and some workers did not understand the new system. They also said people with ulterior motives encouraged people to strike, and that they would take legal action against those who smear the company’s reputation.
In August 2022, White Sand Palace Casino had its casino license renewed.
After many months of denying that illegal confinement was happening in Cambodian scam compounds, a nationwide crackdown on ‘illegal’ gambling commenced in August 2022. This resulted in raids of various gambling locations, including small local gambling rooms and a handful of major compounds that were known to be running illegal online gambling and/or scam operations. Soon after, official statements on the online compounds shifted drastically, and officials began to admit that human trafficking and detention were happening, and that as many as 100,000 people may be involved in ‘illegal gambling’ (officials still appear reluctant to acknowledge that many operations are in fact conducting online fraud). In Sihanoukville, 10 compounds were raided, while others were tipped off that raids were coming, or simply told to stop operating. An exodus of workers from Sihanoukville occurred, with reports that some people moved to compounds in other parts of the country.
After the crackdown commenced, White Sand 2 cleared out. Voice of Democracy (VOD) visited the location as the crackdown was ongoing, and a vendor working outside told reporters it had recently emptied. Previously there had been strict security, but barbed wire had been taken down from the walls and the vendor now described it as ‘like a ghost building.’
Which Actors and Companies Have Been Linked to White Sand?
White Sand Group
White Sand Group (Baisha Group, 白沙集团) and several associated companies were first registered in Cambodia in 2019. The previous year, a batch of companies with the name ‘Bright Beach’ were registered by some of the same actors. Since then, there has been some change in ownership, some companies have been deleted from the company register, and some have changed names. White Sand has had at least three websites during this time, two of which are now inaccessible, and there are as many as 10 Facebook pages branded as White Sand, but it is unclear which are official. One of the company’s now deleted websites listed offices in Cambodia, Vietnam, Malaysia, Myanmar, and Taiwan.
White Sand has been involved in online gambling in Cambodia for several years. A 2015 Phnom Penh Post article on the explosion of online gambling in Sihanoukville described the then partially-open White Sand Palace Hotel as a potential ‘ground-zero for the next big push in live-dealer gaming.’ This was at a time when licensed online gambling was still allowed in Cambodia, prior to the 2019 ban. Sources told the Post that many of the hotel’s more than 300 rooms would be converted into ‘mini online gaming rooms’, and that the investors behind White Sand had rented a further three hotels for the purpose.
The two most prominent individuals linked to White Sand Group in Cambodia’s business registry are Wang Qiang (王強) and Ahr San. Wang Qiang is a Chinese name but the individual is listed in Cambodia’s business registry as a national of Saint Kitts and Nevis, a Caribbean island state that has an ‘investment-for-citizenship’ program, through which investors can obtain a passport that gives them visa-free access to over 140 countries. Ahr San is a Myanmar national linked to 25 companies in Cambodia. The authors were unable to find any further information on these individuals. Chinese-born Yu Lingxiong (俞凌雄) previously held the position of CEO at White Sand Palace, and was a director at four Bright Beach companies until he resigned in 2018 (Ahr San remains their chairman). Yu Lingxiong is returned to later in the profile. A video available online marking the launch of White Sand Palace lists Qiang Ge as president, but this name does not appear on any company registration records.
White Sand has also been involved in crypto currencies, and in 2018 White Sand Palace director Wang Qiang and Malaysian partners launched OurCoin exchange in Kuala Lumpur. OurCoin sought to ‘gradually establish a digital asset ecosystem in Southeast Asia.’ The exchange closed down in 2022. Wang Qiang also joined a global blockchain event in Korea in 2018, where Yu Lingxiong gave the keynote speech and signed an agreement between White Sand and crypto currency firm Wanbo, of which he was also the chairman. It was also reported in 2018 that White Sand had acquired the ECCOIN crypto currency exchange. When it was launched in Cambodia, media reports did not mention White Sand, but the launch was attended by Nop Rothnimol, who delivered a speech saying that ECCOIN would ‘usher in a new era of digital currency in Cambodia.’ Nop Rothnimol is deputy commander of Hun Sen’s Bodyguard Unit and son-in-law of the Bodyguard Unit commander. He has met with Yu Lingxiong on several occasions. His assistant, Chhem Ratanakvisal, and his wife (the daughter of the Bodyguard Unit commander), were previously directors at Global China City Co., Ltd., a company set up by Yu in 2017, but since dissolved. The ECCOIN website is currently non-functioning.
In August 2022, White Sand Palace Casino had its casino license renewed. The license was granted to Fairplay Entertainment Co., Ltd., a company chaired by Ahr San.
White Sand Companies
Company | Chair / Director(s) | Status |
White Sand Group Co., Ltd | Wang Qiang (chair) Ahr San | Active |
David and White Sand Palace Co., Ltd. | Wang Yanxin (chair) Ahr San | Active |
Videos Game White Sand Palace Co., Ltd. | Ma Xiangyu (chair) | Active |
White Sand Palace Property Management Co., Ltd. | Van Veasna (chair) Phan Thi Kim Anh | Changed name to Wisdom Valley Property Management Co., Ltd. in 2022 |
White Sand Land Development Co., Ltd. | Pan Shaoyong (chair) | Changed name to Golden Crystal Co., Ltd in 2022 |
White Sand Palace Hotel Co., Ltd. | Ahr San (chair) | Registered 2012, since deleted from register |
White Sand Maple Leaf Co., Ltd. | Ahr San (chair) | Registered 2019, since deleted from register |
White Sand Real Estate Co., Ltd. | Wang Qiang (chair) Kheang Phamarineth | Registered 2019, since deleted from register |
Source: Cambodia Business Registry, October 2022.
Bright Beach Companies
Company | Chair / Director(s) | Status |
Bright Beach International Group Co., Ltd. | Ahr San (chair) Pov Chumnit (resigned 2018) | Active |
Bright Beach Property Co., Ltd. | Ahr San (chair) Pov Chumnit (resigned 2018) | Active |
Bright Beach Entertainment Co., Ltd. | Ahr San (chair) Pov Chumnit (resigned 2018) | Active |
Bright Beach International Co., Ltd. | Ahr San (chair) Pov Chumnit (resigned 2018) | Registered in 2018, since deleted from company register. |
Note: Pov Chumnit is the Cambodian name of Yu Lingxiong. Source: Cambodia Business Registry, October 2022.
A White Sand promotional video lists a range of properties under the group. In addition to White Sand buildings, it includes Blue Bay Hotel and Oscar KTV (奥斯卡KTV). In June 2022, a Chinese woman died after being stabbed and thrown from the Blue Bay Hotel by her partner. In October another woman died after falling from Blue Bay. In 2021, there was a violent brawl at the Oscar KTV venue that the owner JR Oscar Entertainment Co., Ltd. (JR 奥斯卡娱乐有限公司) publicly apologised for. In July 2022, several media outlets reported that 10 Chinese nationals were rescued from Oscar KTV. This came after a complaint was filed with the police that 13 people were being held in the building. The letter was supported by videos of the 13 people appealing for rescue. The police removed 10 people but denied there was any illegal confinement, although they did not explain why the people appealed to be rescued if they were not being confined. This is covered in the profile here.
Oscar KTV is located opposite White Sand Palace. The month prior to the above rescue, White Sand Group issued a statement saying that it had transferred all of its shares in the company to its ‘original partner’, that all outstanding payables and receivables were the responsibility of that partner, and that Oscar’s relationships with other parties had nothing to do with White Sand. Cambodia’s business register shows that Ahr San resigned her director position at JR Oscar Entertainment Co., Ltd. in February 2022. Online recruitment adverts suggest that the location was being used for online operations prior to Ahr San stepping down.
White Sand and its executives have made substantial charitable donations to the Cambodian Government and the Cambodian Red Cross. On one of its websites, White Sand states that since 2017 it has donated US$1.5 million to the Cambodian Red Cross. The slideshow below highlights some of these donations, which also include donations to Preah Sihanouk provincial administration, court, and police force. White Sand also donated US$20,000 to support the construction of a Covid-19 treatment facility in Sihanoukville. At a Red Cross event in 2019, White Sand Group appeared on stage with Senator Kok An and his son-in-law Rithy Samnang (who feature in profiles on Kaibo, Jinshui, Triumph City, Nanhai, and Crown High-Tech Industrial Park), environment Minister Say Samol, and Preah Sihanouk Deputy Provincial Governor Mang Sineth.
Yu Lingxiong: Crypto Fugitive
Yu Lingxiong (俞凌雄) was born in China but received Cambodian citizenship in 2017 under the name Pov Chumnit (ពៅ ជំនិត). Company registration records show that Yu has been linked to at least 10 companies in Cambodia. As noted above, he was a director at four Bright Beach companies, which are chaired by Ahr San; for a period, he was also the CEO of White Sand Group and was described in company promotional materials as a shareholder.
Yu is a notorious figure, wanted in China for running pyramid schemes and multi-level marketing scams. After leaving China, he launched multiple fraudulent cryptocurrency projects. Soon after arriving in Cambodia, Yu networked with high-level Cambodian actors, and has been photographed with, among others, Prime Minister Hun Sen, his son, Lieutenant General Hun Manet, Deputy Prime Minister Mem Sam An, and Cambodian People’s Party spokesman and National Assembly Member for Preah Vihear, Sous Yara. In 2020, he donated US$50,000 to support Cambodia’s pandemic response efforts, for which he received a letter of thanks from Prime Minister Hun Sen. In 2018, in his capacity as head of the China-Cambodia Business Association, Yu met a delegation from the Jiangsu Provincial Public Security Department of China and a delegation from the Henan Provincial Department of Commerce.
Yu Lingxiong appeared to enjoy a particularly close relationship with the head of Hun Sen’s Bodyguard Unit, General Hing Bun Hieng. In 2017, Yu donated dozens of motorbikes to the Bodyguard Unit. The same year, Yu and the general distributed scholarships and gifts to students at a high school in Kandal Province. In 2017, Yu registered a company in Cambodia called Global China City Co., Ltd. One director at the company was Hing Sokleap (ហ៊ីង សុខលាភ), General Hing Bun Hieng’s daughter and wife of three-star general and deputy commander of the Bodyguard Unit, Nop Rothnimol. Another director was Chhem Ratanakvisal, who is the assistant to Nop Rothnimol. This company has since been deleted from Cambodia’s company register.
Numerous videos of Yu Lingxiong’s motivational speeches can be found online, as well as footage of events that resemble classic pyramid/multi-level marketing pitches, sometimes to rooms of hundreds of people. Some videos include footage of Yu’s meetings in Cambodia. At one meeting with Hun Sen’s personal Bodyguard Unit, he is saluted by a guard of honour on arrival at a banquet.
Yu Lingxiong has been quiet in recent years, and there are rumours that he is either in hiding in Cambodia or has moved to another country. He is the chairman of Jinsha Holding Group (金莎控股集团) which is associated with the Pacific Real Estate / Golden Phoenix Entertainment City scam compound in Kandal (profiled here).
Zhongxing International Holdings Group
White Sand 2 is marked on Google Maps as ‘新城国际娱乐城’ (Xincheng International Entertainment City). According to media reports from 2018, the complex was developed by Zhongxing International Holding Group (众兴国际控股集团). Reports from the ground-breaking ceremony state that this was Zhongxing’s first project in Cambodia. During the early stages of construction, company chairman Shao Zhencai (邵振才) paid a visit to Preah Sihanouk Governor Yun Min, discussing the company’s plans for investment in Sihanoukville and its confidence in the ruling Cambodian People’s Party under the leadership of Prime Minister Hun Sen. Beyond reports of the initial construction, Zhongxing receives no further media coverage and may have divested from the project. The current construction of the White Sand 2 complex falls far short of Zhongxing’s grand plans for a ‘6-star’ office complex.
K99 Group
K99 Group is a Cambodian gambling junket operator owned by Rithy Raksmei, a well-connected Cambodian businessman. It runs gaming junkets at numerous casinos, several of which are reportedly linked to companies implicated in online scam operations (see profile on Nanhai here and Bolai Casino here). It also has developments of its own that are linked to online scam operations and rights abuses (see Triumph City profile here). K99 Group also runs junkets through White Sand Palace, and Rithy Raksmei was seated on the top table at the launch of White Sand Palace.
Location of White Sand
Links to Other Compounds, Companies, and Individuals
White Sand Palace has a relationship with K99 Group, which runs gambling junkets through the White Sand Palace Casino. K99 Group has relationships with other casinos implicated in online scams and illegal detention and reportedly owns a scam compound at Triumph City (see profile here).
Yu Lingxiong is the chairman of Jinsha Holding Group which is associated with the Pacific Real Estate / Golden Phoenix Entertainment City compound in Kandal (see profile here).
White Sand in the news
2022
29 September: Mech, Dara. ‘Amid Ongoing Scam Raids, Sihanoukville Residents Recall Insecurity.’ Voice of Democracy. Link.
Reporters visit well-known fraud compounds amid ongoing crackdown and find most empty, including White Sand 2.
13 September: Podkul, Cezary and Cindy Liu, contributions from Mech Dara, Danielle Keeton-Olsen, and Salina Li. ‘Human Trafficking’s Newest Abuse: Forcing Victims into Cyberscamming.’ ProPublica. Link.
An in-depth investigation into the cyber-scamming industry, the techniques it uses to scam people, and how it ensnares and enslaves workers. Includes testimony from a man held at White Sand with his brother.
11 August: 101 East. ‘Forced to Scam: Cambodia’s Cyber Slaves.’ Al Jazeera. Link.
Longform article focusing on the victims highlighted in the documentary below. Includes two people sold to White Sand.
14 July: 101 East. ‘Forced to Scam: Cambodia’s Cyber Slaves.’ Al Jazeera. Link.
Documentary on some of the main scam compounds located in Sihanoukville and Pursat. Includes testimony from one person who was held at White Sand Palace and one at White Sand 2.
1 April: Li, Yiming 李一鸣. ‘难以逃离的柬埔寨西港“中国城” ：被绑架被倒卖，被威胁“沉尸海底” … [The “China Town” in Sihanoukville, Cambodia, that is Difficult to Escape: Kidnapped, Resold, Threatened to “Sink the Corpse to the Bottom of the Sea” …].’ 北京青年报 [Beijing Youth Daily]. Link.
Newspaper of Beijing’s Communist Youth League reports on the situation in Chinatown, Sihanoukville, documenting the testimony of someone kidnapped and sold to White Sand 2. [Note: The article was removed from the internet around August 2022, but at the time of writing it remains available on some websites].
19 February: ‘逼網詐？男被囚柬埔寨黑屋 拷鐵架床3天3夜 [Forcing Online Fraud? Man Imprisoned in Cambodian Dark Room Tied to Iron Bedframe for Three Days and Three Nights].’ 中國新聞組 [China News Group]. Link.
Taiwan media tells story of 24-year-old from Jiangxi Province who travelled to Cambodia and was sold to White Sand and tied up in a dark room after he refused to work.
18 February: Feng, Shengyong 冯盛雍. ‘最小14岁！多名柬埔寨电诈受害者被救：黑屋被拷数日 电棍铁棒殴打 [Minimum 14 Years Old! Several Cambodian Victims of Online Fraud Were Rescued: Tortured for Days in the Dark Room and Beaten With Electric Batons and Iron Bars].’ 上游新闻 [Upstream News]. Link.
Reporters talk with several people who escaped online scam compounds, including a man kidnapped and sold to White Sand who was tortured when he refused to work.
18 February: Mech, Dara, Cindy Liu, and Danielle Keeton-Olsen. ‘Victims Allege Sihanoukville Precincts with Ties to Major Businesses Are Sites of Scams, Torture, Detention.’ Voice of Democracy. Link.
Accounts of scam operations, forced labour, and human trafficking emerge from a number of Sihanoukville compounds. Article provides accounts of several people who escaped the compounds, including one held at White Sand 2.
17 February: Gu, Yuebing 顾月冰. ‘逃离柬埔寨“网赌之城” [Escape from Cambodia’s “City of Online Casinos”].’ 南方周末 [Southern Weekly]. Link.
Chinese media reports on the scale of online scams operating from Sihanoukville and the conditions in which people are forced to work. Names several compounds as sites for online scam companies, including ‘White Sand 2’.
2021
16 September: Blomberg, Matt. ‘Chinese Scammers Enslave Jobless Teachers and Tourists in Cambodia.’ Thompson Reuters. Link.
Investigation finds foreign workers and tourists stranded in Cambodia during the Covid-19 pandemic trafficked and forced to work in sophisticated Chinese-run online scams, including a Nepali duped into working at White Sand Palace.
15 August: ‘កម្លាំងនគរបាលខេត្តព្រះសីហនុ ឃាត់ខ្លួនជនជាតិចិនចំនួន៤នាក់ ករណី ចាប់ជនជាតិចិនដូចគ្នាចូលរថយន្ត [Sihanoukville Police Detain Four Chinese Nationals for Arresting Chinese Nationals].’ Phnom Penh Reporter. Link.
Police intervene in attempted kidnaping and arrest four Chinese nationals, one of who is described in reports as a manager at White Sand Palace.
2020
2 January: ‘突发！西港白沙皇宫赌场爆发劳工纠纷 数百名工人深夜抗议 [Breaking! Hundreds of Workers Protested Late at Night as Labour Dispute Broke Out at White Sands Palace Casino in Sihanoukville.]’ 柬中时报 [Cambodia-China Times]. Link.
White Sand Palace Casino workers go on strike late at night in front of the hotel.
2019
7 November: ‘揭秘“杀猪盘”：培养感情为“养猪”，卷钱消失是“杀猪”’ [Demystifying “Pig Butchering”: Cultivating Feelings is “Raising Pigs”, and Disappearing Money is “Killing Pigs”].’ 中国青年报 [China Youth Daily]. Link.
Article on the phenomenon of ‘pig butchering’ scams, discusses the case of gang that operated from the Xincheng International building. In April 2019, Cambodian law enforcement and police from Chongqing established a task force to investigate scams being run from the compound. Police found evidence of scams targeting tens of thousands in China, across multiple provinces and valued at over RMB 100 million.
30 May: ‘凶杀！在西哈努克省刺杀中国人，一样国籍的嫌犯被宪兵抓到和被法院关押 [Murder! Assassination of Chinese in Sihanoukville Province, Suspect of the Same Nationality Was Caught by the Gendarmerie and Detained by the Court].’ Fresh News. Link.
Man living at White Sand Palace is arrested for attempted murder after stabbing fellow Chinese.
8 May: Zhu, Qiuyu 朱秋雨. ‘柬埔寨一中国人被枪杀身亡，从车内丢至马路！两中国籍嫌犯被逮捕 [A Chinese in Cambodia Shot and Killed, Thrown from the Car to the Road! Two Chinese Nationals Arrested].’ 南方都市报 [Southern Metropolis Daily]. Link.
Video captures the murder of a Chinese man just after getting into a car outside White Sand Palace.
