On a Sunday afternoon in New York, the sun shines through the gaps in Manhattan high-rise buildings on the walnut wood Long Table of the hotel Suite.
The dull air in the room is split into patches of light and dark.
There are only a few hours left before Asia Session opens on Sunday evening.
The entire global financial market is like a high-pressure container that has been evacuated, just waiting for the first quotation port to burst.
On the temporary workbench on one side of Suite, three high-resolution displays are lined up.
Shen Zhiyi casually pulled her slender and beautiful hair behind her head with a pencil.
A few stray strands of hair were stuck to the side of her slender neck, and her fair face was full of rigor and concentration.
In front of her was a thick stack of the latest regulatory compliance rules issued by the U. S. Commodity Futures Trading Commission (CFTC) and the Chicago Mercantile Exchange (CME).
Next to Shen Zhiyi, Zhang Qingxue accessed the meeting through an encrypted video connection.
Legal Director and Zhang Qingxue, who are Henglong Group, are currently in the office of Shanghai Lujiazui, looking cold and neat.
"Zhiyi, the CFTC just updated a special risk warning at noon today."
In the video, Zhang Qingxue pointed at a line of red letters on the screen, his tone cold and precise,
"Although Silver ETF (SLV) belongs to the securities category Derivatives and is subject to preliminary supervision by the SEC (United States Securities and Exchange Commission),
But its underlying anchored Silver Spot is closely linked to the COMEX Silver Futures contract.
The CFTC's Market Oversight Division (Division of Market Oversight) has launched real-time penetrating review."
Shen Zhiyi's slender fingers tapped quickly on the keyboard, inputting the penetrating supervision logic diagram sent by Zhang Qingxue into Independent Compliance Model.
"Director Zhang, I am calculating the position limits of six SPVs."
Shen Zhiyi stared at the flashing risk indicators on the screen, with a steady and powerful voice,
"According to the CFTC's Speculative Position Limits (Position Limits) rule on Commodity Derivatives,
A single entity or a group of accounts with a concerted action relationship, the net position on Silver Futures and the equivalent Derivatives,
Once there are more than 6,000 lots of Standard Contracts (about 30 million Ounce),
'Large Trader Reporting System'(Large Trader Reporting System) will be triggered automatically."
Zhao Chen came over with a cup of freshly ground sugar-free Americano, placed it gently on Shen Zhiyi's hand, pulled a chair over and sat down next to her.
"Zhiyi, tell me about your defense layout."
Zhao Chen looked at the dense cross-position charts on the screen, with a somewhat intriguing depth in his eyes.
Shen Zhiyi turned his head and smiled sweetly at Zhao Chen, but his eyes instantly returned to the sharpness and ability of a top political and legal student:
"Zhao Chen, although our investment this time is only Over Eighty Million US Dollars,
But on the extreme Out-of-the-Money Call Options (OTM Call), the leverage effect is magnified to the extreme.
Once the silver price rises on Monday and these Options change from virtual value to real value, the equivalent of Silver under our nominal control will instantly explode!
If we place orders according to the traditional single institution, our account will be locked by the CFTC's penetrating system within half an hour.
The regulatory authority may even directly freeze trading authority on the grounds of 'intending to manipulate the market.'"
"So, how are you and Director Zhang going to block this penetration?" Zhao Chen asked with raised eyebrows.
Shen Zhiyi pointed to the transaction structure diagram on the screen and broke it down in detail:
"Director Zhang and I designed a set of 'Three-Layer Offshore Firewall'.
First of all, the six SPV accounts owned by Era Vanguard are registered in Cayman Islands, BVI and Isle of Man.
The Ultimate Beneficial Owner (UBO) structure of six SPVs was legally and compliantly split through Multiple Trusts.
The equity and Voting Rights are completely independent and in no way constitute 'Persons Acting in Concert' in the legal sense."
Shen Zhiyi took a sip of warm water and continued to explain clearly:
"Secondly, at the transaction order issuing end, Lin Lawyer Team passed Algorithmic Trading,
Split the funds of Over Eighty Million US Dollars into tens of thousands of micro-orders.
Strike Price is accurately staggered in four different gradients: 25 US Dollar, 27 US Dollar, 29 US Dollar and 30 US Dollar.
The most important thing is that all orders are hedged with Over-the-Counter Trading (OTC) and Dark Pool (Dark Pool), and orders are not placed directly on the COMEX exchange."
Zhang Qingxue at the other end of the video showed a satisfied smile and answered:
"Zhiyi This structure is very beautifully done.
Even if the CFTC conducted a retrospective audit afterwards, they would only see six unrelated overseas small and medium-sized companies Hedge Fund.
Normal Call Options configuration during retail frenzy.
The Open Interest of a single SPV is always stuck below 85%Warning Line of 'Large Trader Reporting System'.
It didn't touch the regulatory red line, but it also stretched leverage to the limit."
Zhao Chen held Shen Zhiyi's somewhat cold fingers, rubbed them gently, and raised a hint of heartfelt approval at the corner of his mouth:
"Yes, legal compliance is not for litigating, but for tightening the screws of every wave-proof board before the storm comes.
Only with you and Director Zhang checking in, Era Vanguard's hand can grasp it accurately and hard."
Shen Zhiyi pursed his lips shyly, leaned his head on Zhao Chen's shoulder, and said softly:
"This is all taught well by Director Zhang.
I just want to make sure that when you are fighting for Era Vanguard and Henglong,
There will never be a cold arrow behind you that can hurt you."
Su Wantang also walked to Long Table at this time and placed the peeled Nuts in front of the two of them.
Seeing Shen Zhiyi and Zhao Chen tacitly close to each other, a warm smile flashed in their eyes.
"How is the compliance review of warehouse receipt handover at Sister Wantang, Europe and Shanghai?" Shen Zhiyi raised his head and asked.
Su Wantang smiled and said:
"Europe Director Zhang has arranged for a full-time Cross-Border Commodity Compliance Officer to follow up.
The qualifications and Supply Chain purchasing contracts of the Europe manufacturing entities used by Lawyer Lin are all genuine and valid, and can fully withstand regulatory penetration.
At present, these entities are absorbing Pure Nickel Spot warehouse receipts.
It is completely characterized as 'corporate self-rescue stocking in response to the global Supply Chain crisis',
No one has ever linked it to Era Vanguard."
"This makes the perfect Dual Isolation."
Zhang Qingxue summarized it in the video,
"US Stocks and SLV Options end, Zhiyi controls the regulatory risks of CFTC and SEC in New York in real time;
The bulk commodity Spot end is reviewed by Europe Compliance Officer and Lin Lawyer Team stick to cross-border Supply Chain.
Era Vanguard's submarine has now completely submerged to a depth of one hundred meters."
Zhao Chen glanced at World Clock on the wall.
The Monday morning of Tokyo time and Beijing time is coming soon. Asia Session, the first to open in the global financial market, has only the final countdown left.
"Director Zhang, thank you for your hard work. It's midnight in China now. You should go and rest first."
Zhao Chen said to Zhang Qingxue in the video.
"Okay Zhao Zong, if there is any regulatory warning, my team will connect to New York as soon as possible."
Zhang Qingxue simply hung up the encrypted video.
It was quiet again in Suite, with only the faint beeping of the trading system on the screen reminding me that the storm was approaching.
Zhao Chen held Shen Zhiyi's slender waist with one hand, and took Su Wantang's hand with the other.
Looking at the Front-End Derivatives quotation that has started to beat slightly on the screen,
His eyes were as calm as an ancient well with unfathomable depth.
"Zhiyi, Wantang."
Zhao Chen's deep voice sounded in the room,
"The carnival of retail investors is about to begin, and our compliance defense line has been forged.
Tonight, let us see how crazy this trillion-dollar feast of emotions can get."