Analysis of Nanjing Securities' Joint Liability in the ST Nuotai Financial Fraud Case

Based on the search and analysis of information related to the ST Nuotai financial fraud case, I provide a detailed explanation of the potential joint liability that Nanjing Securities may bear in this case.

Jiangsu Nuotai Aosainuo Biopharmaceutical Co., Ltd. (stock code: 688076) received an administrative penalty decision from the CSRC on December 18, 2025 due to financial fraud [1]. Meanwhile, the Shanghai Stock Exchange also issued a disciplinary action decision against ST Nuotai and related responsible persons [2].

As the sponsor institution of ST Nuotai, Nanjing Securities may bear the following joint liabilities in this case:

1. Warning and Fine
   • According to Article 182 of the Securities Law of the People’s Republic of China, if a sponsor issues a sponsorship letter or other documents with false records, misleading statements, or major omissions, its business income shall be confiscated and a fine of 1 to 5 times the business income shall be imposed
   • The directly responsible persons shall be given a warning and a fine of 30,000 to 300,000 yuan

2. Suspension or Revocation of Sponsorship Business License
   • If the circumstances are serious, the CSRC may suspend or revoke the relevant business license

1. Joint Compensation Liability to Investors
   • According to the Provisions of the Supreme People’s Court on Trying Civil Compensation Cases Arising from False Statements in the Securities Market, the sponsor institution shall bear joint and several liability for compensation with the issuer
   • As the sponsor institution, Nanjing Securities shall bear joint and several liability for compensation for investors’ investment losses

2. Pre-compensation Liability
   • In practice, the sponsor institution usually needs to pre-compensate investors for their losses before recovering the amount from the issuer

If Nanjing Securities has intentional or gross negligence in the sponsorship process, the relevant sponsor representatives may face:

• Crime of Fraudulent Securities Issuance
  : Imprisonment for not more than five years or criminal detention, and a fine of not less than 1% but not more than 5% of the illegally raised funds, or a separate fine
• Crime of Issuing Grossly False Certification Documents
  : Imprisonment for not more than three years or criminal detention, and a fine or a separate fine

The degree of legal liability that Nanjing Securities will ultimately bear depends on the following factors:

• Intentional
  : Issuing a sponsorship opinion knowing that the issuer has financial fraud
• Gross Negligence
  : Failing to perform necessary verification obligations and failing to detect obvious signs of financial fraud

• Whether due diligence is sufficient
• Whether verification procedures are complete
• Whether reasonable suspicion is maintained regarding abnormal financial indicators

• If the fraudulent act is highly concealed and even professional institutions find it difficult to detect, the liability may be appropriately reduced
• If the fraudulent act obviously violates accounting standards, the sponsor institution cannot shirk its responsibility

From the search results, it can be seen that the CSRC has continuously increased the penalty intensity for sponsor institutions involved in financial fraud cases in recent years [4]. Typical cases include imposing huge fines on multiple securities firms for failing to perform their duties diligently and requiring them to bear investor compensation liability.

Overall, Nanjing Securities is likely to bear the following joint liabilities in the ST Nuotai financial fraud case:

1. Administrative penalties
   : Including warning, confiscation of business income and imposition of fines
2. Civil compensation
   : Bearing joint and several liability for compensation to investors who suffered losses due to financial fraud
3. Reputational damage
   : The sponsorship business qualification may be affected, and the practice qualifications of relevant sponsor representatives may be restricted

It is recommended that investors pay close attention to the CSRC’s official penalty decision on Nanjing Securities to obtain more accurate liability determination information.

[1] CSRC Administrative Penalty Decision - Jiangsu Nuotai Aosainuo Biopharmaceutical Co., Ltd. (December 18, 2025)
[2] Shanghai Stock Exchange Disciplinary Action Decision - ST Nuotai and Related Responsible Persons
[3] Nanjing Securities’ Relevant Commitment Documents Regarding ST Nuotai’s IPO and Issuance
[4] Analysis of CSRC’s Penalty Cases Related to Financial Fraud Investigations