She had made Chiu Bing Keung Kenneth of the U.K. responsible for managing 11 subsidiaries of Van Thinh Phat, including six overseas, and he created fake contracts between these companies to move VND34 trillion out of and into Vietnam between 2014 and 2022.
The other man, Chen Yi Chung, acting CEO of Saigon Commercial Bank (SCB), sent $674 million overseas and received $35 million through 13 transactions in 2020 and 2021, the police said.
All the money was moved on behalf of property developer Van Thinh Phat, of which Lan was the chairwoman.
Lan confessed that she told Chung to create fake contracts for these transactions in collaboration with her company and SCB.
Both men have left Vietnam and their current whereabouts are unknown.
They accounted for part of the $4.5 billion in cross-border transactions that Lan and her accomplices carried out illegally between 2012 and 2022.
Lan has claimed they were loans she received from abroad and repayment of debts.
The police have recommended that she be charged with fraudulent appropriation of assets, money laundering and illegal cross-border currency transfers.
Thirty three others face at least one of those charges.
Lan received the death penalty in April at another trial, this one for causing a loss of VND677 trillion ($27 billion) to SCB. She has appealed.