Chinese state-owned enterprise “COFCO Corporation” has been accused of “illegally bypassing regulations” to list in the United States and has been investigated by the China Securities Regulatory Commission (CSRC). This is the first case since the implementation of the “Trial Measures” by the CSRC on April 24, with several related companies also facing penalties.
According to reports from the China Fund News and Economic Observer Network, on December 21, 2024, COFCO Corporation submitted a report entitled “Filing Report on Intending to Realize Indirect Listing on the Nasdaq Stock Exchange in the United States through De-SPAC Acquisition Transaction” to the CSRC through its domestic operational entity, China National Cereals, Oils and Foodstuffs Corporation (Cofco Group).
The CSRC officially received the filing materials on March 6, 2025, and requested additional information from Cofco Group. However, Cofco Group and other relevant entities failed to complete the procedures for overseas listing filing. On October 1, 2025, by merging with a special purpose acquisition company, they illicitly listed on the Nasdaq Stock Exchange.
Upon discovering this violation, the CSRC promptly reported the situation to regulatory authorities in the United States and the exchange through the cross-border regulatory cooperation mechanism. COFCO Corporation halted trading on the day of its listing and remains suspended as of April 24, 2026.
According to official announcements, China National Cereals, Oils and Foodstuffs Corporation failed to comply with the prescribed procedures for domestic enterprises seeking overseas listings, engaging in unauthorized activities of overseas issuance and listing, which is suspected of violating relevant provisions of the “Trial Measures.”
Authorities plan to impose the following penalties on the involved entities: a fine of 3 million yuan on China National Cereals, Oils and Foodstuffs Corporation and a fine of 1.5 million yuan on the person directly responsible for the filing, Jiang Zhenjun. Guangdong Xinyu Law Firm, acting as an intermediary institution, faces a fine of 500,000 yuan, and lawyer Li Huabin, who provided legal advice, faces a fine of 200,000 yuan.
Beijing financial lawyer Wei Jingfeng stated in an interview with the Huaxia Times that the CSRC’s regulation of the filing for domestic enterprises seeking overseas listings helps eliminate regulatory gaps and prevents risks such as data security breaches and cross-border interest transfer.
However, COFCO Corporation is not the first case of a company listing overseas under the pressure of regulation. The Chinese ride-hailing giant Didi Chuxing was listed on the New York Stock Exchange on June 30, 2021. Shortly after its listing, the Cyberspace Administration of China cited “serious violations of laws and regulations in collecting personal information,” leading to the removal of the app from various app stores and strict rectification requirements for Didi Chuxing.
According to The Wall Street Journal, sources revealed that in the weeks leading up to Didi Chuxing’s US listing, Chinese cybersecurity regulators suggested that they postpone their IPO and conduct a thorough self-examination of their network security. However, Didi Chuxing chose to proceed without a direct order from the authorities to halt the IPO.
The Chinese government has long used laws aimed at protecting national security and state secrets to prevent US regulatory agencies from reviewing the audit documents of Chinese companies.
Commentator Zhu Ming from The New York Times pointed out that the Chinese government’s claims of protecting sensitive data and networks are merely to maintain control, persecute dissidents, and religious groups. He stated, “The hammering of Didi is not about data protection; it is a stance of the Chinese Communist Party, provoking and testing the US regulatory system, while also fearing the collapse of power if a crack is opened.”