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China Regulator Imposes First Penalty for Unauthorized Overseas Listing

Published: Apr. 25, 2026  12:15 a.m.  GMT+8
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The Heilongjiang bureau of the CSRC plans to fine Heilongjiang Zhongneng Liangke Agricultural Technology Co. Ltd. 3 million yuan. Photo: VCG
The Heilongjiang bureau of the CSRC plans to fine Heilongjiang Zhongneng Liangke Agricultural Technology Co. Ltd. 3 million yuan. Photo: VCG

China’s securities regulator has penalized a domestic company for listing on a foreign exchange without completing the required regulatory filing, marking its first enforcement action of this kind.

The case underscores Beijing’s strict enforcement of oversight rules designed to monitor and control how domestic companies raise capital in international markets.

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  • CSRC fines Heilongjiang Zhongneng Liangke 3M yuan ($439k) for unauthorized Nasdaq listing via SPAC on Oct 1, 2025; first such penalty.
  • Shares of Zhong Guo Liang Tou suspended after CSRC alerted US regulators; fines for executive (1.5M yuan), law firm (0.5M), lawyer (0.2M).
  • 257 issuers await CSRC approval as of Apr 17; 152 received notices in 2025.
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Who’s Who
Heilongjiang Zhongneng Liangke Agricultural Technology Co. Ltd.
Heilongjiang Zhongneng Liangke Agricultural Technology Co. Ltd., domestic entity of Zhong Guo Liang Tou Group Ltd., faces a 3 million yuan ($439,000) fine from CSRC's Heilongjiang bureau for its Nasdaq listing (Oct. 1, 2025, via SPAC) without completing required filing. Shares suspended on debut after CSRC alert to U.S. regulators.
Zhong Guo Liang Tou Group Ltd.
Zhong Guo Liang Tou Group Ltd. listed on Nasdaq via SPAC merger on Oct. 1, 2025, without completing CSRC filing. Its domestic entity, Heilongjiang Zhongneng Liangke, faces a 3M yuan ($439K) fine—the first such penalty. Shares suspended on debut after CSRC alerted US regulators. (47 words)
Guangdong Xinyu Law Firm
Guangdong Xinyu Law Firm, legal counsel for Zhong Guo Liang Tou Group Ltd., faces a proposed 500,000 yuan ($73,000) penalty from the CSRC for the company's unauthorized Nasdaq listing without completing required filings.
Beijing Dacheng (Chengdu) Law Firm
Beijing Dacheng (Chengdu) Law Firm issued a legal opinion for Wetouch Technology Inc.'s Nasdaq Capital Market transfer in Feb 2024 without CSRC filing, arguing board transfers weren't regulated. This prompted CSRC to mandate such filings.
Wetouch Technology Inc.
Wetouch Technology Inc. transferred its stock from a U.S. over-the-counter market to the Nasdaq Capital Market in February 2024 without CSRC filing. A legal opinion from Beijing Dacheng (Chengdu) Law Firm claimed board transfers were not explicitly regulated, prompting CSRC to mandate filings for such moves.
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