The actual controller of the listed company actually had a penalty for the insider trading of its own stock Xu Yusuo: the confiscation of more than 5.4 million yuan was fined more than 16 million yuan.

Our reporter Zhu Baozhen

The confiscation of insider trading illegal income of more than 5.4 million yuan, and imposed a fine of more than 16 million yuan, warned two short-term trading behavior, and imposed a fine of 200,000 yuan, while taking five years of securities market ban measures.

This is the punishment of the CSRC Xu Yusuo.

How come inside information?

Let's first take a look at Xu Yusuo.

Securities Regulatory Commission issued the administrative penalty decision like this article: Xu Yu lock, male, born in February 1965, the founder of Shenzhen City Yuanwang Valley 002 161, Information Technology Co., Ltd. attending shares (hereinafter referred to as Invengo), the actual control People, the address is Nanshan District, Shenzhen City, Guangdong Province.

So, what did Xu Yusuo do? What are the illegal facts? We will sort out this one by one.

The first thing to introduce is the situation in which Xu Yusuo controls the insider trading of “Liao Mosong” account “Yuanwang Valley”.

Speaking of this, we must first talk about the formation of insider information has been known to Xu Yusuo inside information.

Let us first trace the time to 2014.

In 2014, Xu Yusuo learned about BibliotheCA GrouPG mbH, the leading company in the international library market. On August 28, 2014, Xu Yusuo, Yuanwanggu Secretary and Investment Manager made initial contact with Bibliotheca GroupGmbH shareholders to discuss the valuation and investment structure of Bibliotheca Group GmbH. On September 11, 2014, the two parties signed a confidentiality agreement. On October 23, 2014, the two sides held talks again. Yuanwang Valley proposed preliminary acquisition intentions, including valuation methods and investment structure, and initially determined the purchase price of 100 million euros.

In the blink of an eye, we will enter 2015. On January 22 of the same year, the two parties negotiated again and agreed to draft an investment from Yuanwang Valley in accordance with the valuation method of Bibliotheca Group GmbH's EBITDA 10 times and the investment structure of the four-phase acquisition. Letter of intent. On March 18, 2015, both parties confirmed their investment intentions and reached an agreement on the unconfirmed terms in the investment letter of intent. On March 25, 2015, the two parties formally signed an investment letter of intent, stipulating that Yuanwang Valley will acquire 100% of the shares of Bibliotheca Group GmbH in 4 shares, and the amount of funds will be no less than 95.5 million euros. On March 26, 2015, Yuanwang Valley issued a notice to plan major events, and the company's shares were suspended from the same day. On May 14, 2015, Yuanwang Valley issued an announcement to terminate the planning of this major asset restructuring. The company's shares will resume trading as of the date.

Here, Yuanwang Valley intends to invest at least 95.5 million euros in 4 shares to purchase 100% of the shares of Bibliotheca Group GmbH, which is a major event under Article 67(2)(2) of the Securities Law, in accordance with the Securities Law. The provisions of Article 75, paragraph (1), are inside information. The inside information is formed no later than September 11, 2014 and is published on May 14, 2015. Xu Yusuo, the actual controller of Yuanwang Valley, is the main decision maker and promoter of this major asset reorganization. He is involved in the acquisition and is inside information insider. The time for knowing inside information is no later than September 11, 2014.

How to control the use of "Liao Mosong" account?

So, what is the situation of Xu Yusuo controlling the use of the "Liao Mosong" account? Let's continue reading:

First, the "Liao Mosong" account transaction MAC address is partially matched with the office computer that Yuanwang Valley provides to Xu Yusuo and the MAC address of Xu Yusuo's home computer; the IP address of the account transaction and the IP address of the foreign export of Yuanwang Valley. coincide.

Secondly, the "Liao Mosong" account and the "Xu Mouyang" (Xu Yusuo's son) securities account have a large number of orders using the same IP and MAC address, and the same use of "Chen Mou" (Xu Yusuo's wife) securities account The case of placing the same IP address and MAC address.

Third, the only two mobile phone orders placed in the "Liao Mosong" account were ordered by Xu Yusuo 138XXXX1841 mobile phone number.

Fourth, from November 28, 2012 to October 17, 2014, the IP address of the order placed in the “Liao Mosong” account is basically Singapore, which coincides with Xu Yusuo in the United States and Singapore during this period; June 2015 The IP address of the order placed in the "Liao Mosong" account coincides with the travel schedule of Xu Yusuo during this period.

Fifth, the funds of the "Liao Mosong" account are all directly from Xu Mouyang, and ultimately come from Xu Yusuo. The funds go to Xu Yusuo, Chen Mozhu, Xu Mouyang and Li Mouwen (Chen Mou's daughter-in-law) . Sixth, Liao Mosong and Xu Yu are locked in relatives. The telephone number left by the account of Liao Mosong is accounted for by Chen Mouzhu’s mobile phone number. The address reserved is Yuanwang Valley.

On February 2, 2015, Xu Yusuo controlled the “Liao Mosong” account to buy 250,000 shares of “Yuanwang Valley”. The IP address of the transaction was the external export IP address of Yuanwanggu, and the MAC corresponding to the order computer. The address is in the list of company computer MAC addresses provided by Yuanwang Valley. On June 4, 2015, the account sold all the above-mentioned stocks. After deducting the relevant taxes and fees, the insider trading “Yuanwang Valley” during the “Liao Mosong” account involved in the case actually earned 5424446.93 yuan.

In addition, the China Securities Regulatory Commission also found that Xu Yusuo controlled two short-term transactions in the "Liao Mosong" account "Yuanwang Valley": Since the Wangwang Valley was listed in August 2007, Xu Yusuo has been a shareholder with more than 5% of its shares. During the period, Xu Yusuo controlled to use the “Liao Mosong” account to trade “Yuanwang Valley” twice from July 20, 2013 to July 20, 2015. There is “selling within six months after buying, or selling The act of buying again within six months after the formation constitutes a short-term transaction.

What are the characteristics?

What characteristics are presented in this case? In this regard, the case handlers also gave a detailed introduction.

Feature 1: The actual control of insider trading by listed companies, the nature of illegal acts is bad.

The case handler told the "Securities Daily" reporter that in this case, the party Xu Yusuo was the actual controller of Yuanwang Valley, and served as the chairman and general manager of the company for a long time. After the suspected unit bribery, he was no longer in Yuanwang Valley in December 2012. During his tenure, he should clearly understand and consciously abide by securities laws and regulations, and commit to the long-term development of the company and enhance the standardization of the company. However, since the beginning of the listing of Yuanwang Valley in 2007, Xu Yusuo has actually controlled the use of his distant relatives, Liao Mosong’s securities account, to frequently trade “Yuanwanggu” stocks, engaging in short-term trading and insider trading, and the nature of illegal acts is bad.

Feature 2: One wave is not flat, and one wave starts again. The parties choose to fight against the end.

The case handler told the reporter that Xu Yusuo fled from October 24, 2012 to November 27, 2014 on suspicion of bribery. On October 10, 2014, the Supreme People's Law, the Supreme People's Procuratorate, the Ministry of Public Security, and the Ministry of Foreign Affairs jointly issued the "Notice on Urging the Economic Crimes of Escaped Offenders Outside the Country". According to the notice, from the date of publication of the notice to 2014 12 If you voluntarily surrender your crimes before the 1st of the month and voluntarily return to your country, you may be given a lighter or mitigated punishment according to law. On November 28, 2014, Xu Yusuo surrendered to China. Xu Yusuo was in contact with Company B during the period of absconding and began to promote the acquisition. At the beginning of the investigation of this case, Xu Yusuo’s judicial procedure for the bribery of the above-mentioned units has not yet ended. The old things have not happened, and new things have come again, which has a great impact on Xu Yusuo. Therefore, Xu Yusuo is recalcitrant and refuses to admit the illegal facts.

How to investigate the case?

So how is this case investigated? I think everyone is very concerned. Let's listen to what the case handlers are saying.

On July 20, 2015, according to the abnormal transaction situation discovered by the Exchange, the Shenzhen Bureau of the CSRC initiated a preliminary investigation on the suspected insider trading “Yuanwang Valley” case. After the Shenzhen Bureau took over the case, it immediately formed an investigation team to discuss the case, carefully and carefully prepare the investigation plan, and completed the investigation and evidence collection of insider information content, sensitive period, and insider's scope within one week after taking over the case. The success of the investigation has laid a solid foundation. After obtaining the actual controller and source of funds of the account involved through the external investigation and evidence collection, the investigation team quickly found out that there was a relationship between Xu Yusuo and Liao Mosong’s account, and initially grasped the fact that Xu Yusuo borrowed the insider trading of “Secret Valley” from other securities accounts. .

There are a few things worth mentioning here.

Event 1: The party concealed the order computer to hinder the investigation.

According to the investigators, with the in-depth analysis of the transaction records of Liao’s securities account, the investigation team found that the transactions in the Liao’s securities account suspected of insider trading were placed in the Yuanwang Valley company using office computers, and the investigation team immediately went to the office. Yuanwang Valley Company looked for the computer. However, the investigators did not find the computer in Yuanwanggu, and the computer in Xu Yusuo’s office was removed.

Event 2: Focus on objective evidence and determine the account control relationship in the case of “zero confession”.

Xu Yusuo was the main decision maker and promoter of Yuanwanggu's major asset restructuring, and participated in the acquisition. He knew that insider information could not be disputed, so Xu Yusuo took the approach of denying the account control relationship to deal with the investigation.

However, Xu Yusuo has a strong sense of counter-investigation. In this regard, the investigators decided to analyze the evidence from the objective evidence to analyze the control relationship of the account. For example, when investigating the account of Liao Mosong, the investigation team extended the investigation of the existing Xu Moyang (the son of Xu Yusuo) account and found that there is a high degree of convergence between the two. The investigation team immediately talked about Xu Yusuo, Xu Yusuo explained that it promoted the far The situation of Wanggu’s reorganization was also acknowledged by the actual use of Xu’s account (Xu’s account has never been traded “Yuanwang Valley”).

After curing Xu Yusuo’s control of Xu’s account, the investigators began to ask about the account of Liao’s account. Xu Yusuo began to feel uneasy and said that he did not know Liao Mosong. The investigators immediately showed them Liao Mosong and Xu Mouyang. Evidence that the account transaction is highly convergent, Xu Yusuo suddenly paused, and after a long silence, he said that he could not remember it, and asked for another day to explain.

In the end, based on the multi-faceted objective evidence on the basis of full argumentation and reasoning, the investigation team determined that the Liao Mosong account was actually controlled and used by Xu Yusuo, and the account control relationship was determined in the case of “zero confession”.

Event 3: From all sorts of refusal to find someone to "top package."

At the beginning of the investigation, Xu Yusuo insisted that he did not know Liao Mosong, did not understand the situation of Liao Mosong's securities account, and Liao Mosong said that his account entrusted a friend from Singapore to help. As the investigators pointed out the relationship between Xu Yusuo and Liao Mosong's accounts one by one, Xu Yusuo and Liao Mosong also said that the two were distant relatives, Xu Yusuo transferred to Liao Mosong to lend money to Liao Mosong. With the deepening of the investigation, Xu Yusuo gradually realized that it was impossible to easily evade the accountability, so he arranged for Liao Mosong to acknowledge that the account was operated by Liao Mosong and attempted to abandon the car. The investigation team always insisted on attaching importance to objective evidence, and carefully observed the statements of the parties with obvious interests. Through careful analysis and argumentation of the objective evidence, it was finally determined that the account of Liao Mosong was actually controlled by Xu Yusuo and successfully investigated the case.

What effect has it achieved?

As the actual controller of Yuanwang Valley, Xu Yusuo controlled the frequent trading of Liao Mosong account from Yuanwang Valley in 2007, and there were a large number of illegal activities in window trading and short-term trading, which were not discovered for a long time. The amount of illegal gains in insider trading was huge, and the nature of illegal acts was bad. The CSRC imposed heavy penalties on Xu Yusuo according to the standard of “no penalty for three”, accumulatively fined more than 21 million yuan, and imposed a ban on securities market for Xu Yusuo for 5 years.

The successful investigation and punishment of this case shows that the illegal entities of insider trading include not only the management of listed companies, the target parties of major asset restructuring, but also the intermediary controllers of listed companies. The actual controllers of listed companies may also take risks to engage in insider trading activities. I will investigate the insider trading behavior without any dead ends, full coverage, zero tolerance, and impose heavy penalties on the insider trading behavior of the actual controller of the listed company. The investigation and investigation of this case demonstrates the determination and ability of the CSRC to crack down on insider trading violations. The offenders paid the due price and also greatly shocked the market participants.

In recent years, the CSRC has always regarded investigating and cracking down on insider trading as the focus of auditing and law enforcement. The situation of insider trading of statutory insider information has been reduced, and the situation of insider trading cases in the field of mergers and acquisitions has been effectively curbed.

The reporter learned that in order to effectively maintain an open, fair and just market order and further curb the above-mentioned violations of insider trading violations, according to the overall deployment of the special enforcement actions of the CSRC in 2017, the CSRC inspection department recently deployed 18 insider trading cases. As the third batch of special operations, the organization was investigated and dealt with.

The CSRC reminded that insider trading seriously undermines the fair trading order of the market and seriously damages the legitimate rights and interests of investors. It is a serious fraud in the securities market. It is always the focus of the CSRC's inspection and enforcement, and it is also the focus of joint prevention and control by the society and the market. The insiders of listed companies and the relevant personnel who know the inside information due to their duties or work conveniences must strictly observe the professional ethics red line and the legal bottom line, and do not disclose inside information or suggest others to buy or sell stocks. No unit or individual can be lucky, profit-seeking, risk-testing, and using insider information to trade stocks for illegal gains. Investors should consciously do not inquire about internal news, do not listen to the message, and insist on rational investment.

It is reported that, in the next step, while serious investigation and handling of cases, the CSRC and the relevant departments of public security, discipline inspection and supervision, state-owned assets supervision and other relevant departments will continue to implement the "Opinions on Cracking and Preventing Insider Trading in the Capital Market According to Law" to further promote the integration of insider trading. The construction of the prevention and control system has always maintained a high pressure on insider trading.

(Zhu Baozhen)

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