China Grain Investment plans to list on the US stock market. The China Securities Regulatory Commission requires supplementary explanations regarding whether its business operations involve areas restricted or prohibited for foreign investment

According to the Zhitong Finance APP, on March 21, the China Securities Regulatory Commission (CSRC) released the "Supplementary Material Requirements for Overseas Issuance and Listing Filing Public Notice (March 14, 2025 - March 20, 2025)," in which the International Department of the CSRC issued supplementary material requirements for 18 companies. The notice mentioned that China Grain Investment is required to provide additional explanations regarding whether its business operations involve areas restricted or prohibited for foreign investment. Data shows that on October 2, 2024, China Grain Investment Group Co., Ltd. and its subsidiary Rosey Sea Holdings Limited signed a merger agreement with the SPAC company Iron Horse Acquisitions Corp. (IROH), intending to go public on the NASDAQ in the United States through a SPAC reverse merger.

The CSRC requests the company to supplement the following matters and asks the lawyer to verify and provide clear legal opinions:

1. The compliance of the company's equity control structure, including but not limited to the specific circumstances of domestic individuals and foreign-invested enterprises involved in the establishment and return investment, as well as the fulfillment of foreign exchange management, overseas investment, and foreign investment regulatory procedures, and whether it complies with the "Regulations on Foreign Investors Merging Domestic Enterprises."

2. The company's compliance operation situation: (1) Whether the business operations involve areas restricted or prohibited for foreign investment and whether the necessary qualifications and permits have been obtained. (2) The reason for the daily average patent authorization of the domestic operating entity being prior to the establishment date. (3) Basic information about distributors, the actual operation situation and compliance of the distributor model. (4) A list explaining the specific circumstances of major contracts such as procurement and sales contracts, including parties to the contract, contract amounts, performance status, etc.

3. The tax declaration and payment situation of the company's merger transaction with IROH in accordance with the "Announcement on Several Issues Concerning the Enterprise Income Tax on Indirect Transfer of Property by Non-Residents."

China Grain Investment Group Co., Ltd., as an agricultural enterprise integrating food biotechnology and health product research, development, production, and sales, advocates a green and healthy consumption concept, aiming to become a leading online and offline health food sales group in Asia and internationally