252 unchanged sentences
asset exchanges associated with Russian and/or North Korean nationals.
+Added: Our business operations are not currently
+Added: impacted by the cryptocurrency restrictions imposed by the Chinese government (collectively, the “PRC Crypto Restrictions”)
+Added: in any material respect, even though the Chinese government has adopted an increasingly stringent approach in recent years, as outlined
+Added: and discussed below.
+Added: On December 3, 2013, the People’s Bank
+Added: of China, China’s central bank (“PBoC”), issued the Notice on Preventing Risks Associated with Bitcoin , emphasizing
+Added: that Bitcoin should be deemed as a virtual commodity rather than a fiat currency.
+Added: This notice prohibits financial and payment institutions
+Added: in China from providing Bitcoin-related services, highlighting the potential risks of money-laundering associated with Bitcoin.
+Added: Further tightening the regulatory environment,
+Added: on September 4, 2017, the PBoC issued the Announcement on Preventing Risks Associated with Financing Activities through ICOs ,
+Added: which prohibits the initial coin offerings (ICOs) which was characterized as a potentially criminal activity, potentially involving suspected
+Added: illegal issuance and sales of tokens and notes, unauthorized public issuance of securities, illegal fundraising, financial fraud, and
+Added: Ponzi schemes.
+Added: The most recent regulatory measure came on
+Added: September 24, 2021, when the PBoC, along with nine other Chinese national government bodies, issued the Notice Regarding Further Prevention
+Added: and Management of Risks Associated with Cryptocurrency Trading Hype banning overseas cryptocurrency exchanges from providing services
+Added: to residents in mainland China.
+Added: This notice also prohibits individuals in mainland China from working for overseas exchanges, and restricts
+Added: companies and individuals from providing marketing, payment, settlement services or technical support to these exchanges.
+Added: A comprehensive
+Added: monitoring system was also established to oversee cryptocurrency activities of individuals and companies in mainland China, giving local
+Added: authorities extensive authority to monitor their regions and raise early warning flags.
+Added: We believe our business operations are not
+Added: currently subject to these PRC Crypto Restrictions.
+Added: We are not a PRC company, nor do we have any PRC subsidiaries.
+Added: We are not a financial
+Added: or payment institution operating within China either.
+Added: We currently do not conduct any business activities within China.
+Added: We do not engage
+Added: in any exchange business between fiat currency and cryptocurrency or among cryptocurrencies.
+Added: We do not issue digital tokens through ICOs
+Added: or otherwise, nor do we provide marketing, payment, settlement services or related technical support for any cryptocurrency exchanges.
+Added: Our involvement with Bitcoin is limited to
+Added: purchasing, holding and selling Bitcoins, which is not prohibited under the PRC Crypto Restrictions.
+Added: Furthermore, the holding of certain
+Added: executive roles by Chinese citizens in our company does not violate any PRC Crypto Restrictions.
+Added: While our current business operations are
+Added: not subject to the PRC Crypto Restrictions, future changes in our business strategies or operations could expose us to these restrictions.
+Added: In addition, the PRC Crypto Restrictions are continuously evolving and can be subject to significant changes.
+Added: There is a possibility
+Added: that the Chinese government may broaden its regulatory scope to include a wider range of cryptocurrency-related activities, potentially
+Added: impacting companies operating outside of China.
+Added: If new regulations are introduced or if our business evolves to include activities that
+Added: fall under the PRC jurisdiction, we could face increased regulatory scrutiny, compliance costs or operational restrictions, which, in
+Added: turn, could materially affect our current or anticipated business operations.
As noted above, activities involving Bitcoin
17 unchanged sentences
On March 24, 2021, the SEC adopted interim final
−Removed: rules relating to the implementation of certain disclosure and documentation requirements of the Holding Foreign Company Accountable Act,
−Removed: or the HFCAA.
+Added: rules relating to the implementation of certain disclosure and documentation requirements of the Holding Foreign Company Accountable
+Added: Act, or the HFCAA.
An identified issuer will be required to comply with these rules if the SEC identifies it as having a “non-inspection”
13 unchanged sentences
in the HFCAA.
−Removed: The rules apply to registrants that the SEC identifies as having filed an annual report with an audit report issued by a
−Removed: registered public accounting firm that is located in a foreign jurisdiction and that PCAOB is unable to inspect or investigate completely
+Added: The rules apply to registrants that the SEC identifies as having filed an annual report with an audit report issued by
+Added: a registered public accounting firm that is located in a foreign jurisdiction and that PCAOB is unable to inspect or investigate completely
because of a position taken by an authority in foreign jurisdictions.
614 unchanged sentences
Not applicable as we are a smaller reporting company.
−Removed: UNRESOLVED STAFF COMMENTS
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.