Analysis of the Criminal Review of Ganfeng Lithium's Insider Trading Case and Its Impact on Spin-Off Listing

Based on the latest information searched, I will analyze in detail the transfer of Ganfeng Lithium’s insider trading case to criminal review and its impact on the spin-off listing of Ganfeng Lithium Battery.

Time Node	Event Content
June 2020	Ganfeng Lithium began merger and acquisition negotiations with Jiangte Motor (formerly *ST Jiangte), which was on the verge of delisting. Chairman Li Liangbin and Secretary of the Board Ouyang Ming visited Jiangte Motor for an inspection
June 22, 2020	RMB 30 million was transferred into Ganfeng Lithium’s securities account
June 23 - July 2, 2020	Cumulatively purchased 15.6777 million shares of Jiangte Motor, costing RMB 26.4838 million, cashed out RMB 27.6329 million, Profit of RMB 1.1053 million
July 2024	The Jiangxi Securities Regulatory Bureau imposed administrative penalties: confiscation of illegal gains of RMB 1.1053 million, a fine of RMB 3.3159 million; a fine of RMB 600,000 on Li Liangbin and a fine of RMB 200,000 on Ouyang Ming
December 29, 2025	The Yichun Municipal Public Security Bureau served the prosecution transfer notice, suspected of unit crime of insider trading , and the case was officially transferred to the procuratorate for review and prosecution

According to Article 180 of the Criminal Law, the crime of insider trading:

• Those with serious circumstances
  : Shall be sentenced to fixed-term imprisonment of not more than five years or criminal detention, and shall also be fined not less than one time but not more than five times the illegal gains;
• Those with especially serious circumstances
  : Shall be sentenced to fixed-term imprisonment of not less than five years but not more than ten years, and shall also be fined not less than one time but not more than five times the illegal gains

Although the illegal gains were only RMB 1.1053 million, the regulatory authorities are advancing criminal accountability based on the “zero tolerance” principle. The

means the company may face fines, and relevant responsible persons may bear criminal liability.

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According to the “Rules on Spin-Off Listing of Listed Companies”

:

If a listed company or its controlling shareholder, actual controller has received an administrative penalty from the CSRC within the most recent 36 months,

it shall not spin off its subsidiary for listing

[1]

:

Time Node	Status
July 2024	Ganfeng Lithium received an administrative penalty (36-month restriction period began)
December 31, 2025	The restriction period has not expired
July 2027	The restriction period expires

This means

, directly blocking the spin-off listing path.

Ganfeng Lithium Battery was established in 2011, and introduced industrial capital through

between 2020 and 2022[1]:

Investor	Type
Xiaomi Industrial Investment	Strategic Investment
Dongfeng Motor	Strategic Investment
Changan Automobile	Strategic Investment
Anker Innovations	Strategic Investment
OPPO, Transsion Holdings	Industrial Capital

: If a qualified IPO is not realized by the end of 2025, investors may require the actual controller to repurchase shares. As the IPO VAM period expired on December 31, 2025, this clause has .

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In March 2025, Ganfeng Lithium launched a share repurchase plan[2]:

• Total Repurchase Amount
  : RMB 1.6 billion
• Repurchased Shares
  : No more than 499 million shares
• Covered Shareholders
  : 28 investors
• Repurchase Price
  : Based on an annualized 6% return benchmark

: 23 strategic investors chose to completely exit, including:

• Xiaomi Changjiang Industrial Fund
• GoodWe
• Anker Innovations
• Jiemu Ventures
• Jiahe Electroacoustics
• Xinzhifeng Investment and other well-known institutions[3]

According to Ganfeng Lithium’s guarantee announcement on January 4, 2026[3]:

Subsidiary	Asset-Liability Ratio
Ganfeng Lithium Battery	71.71%
Dongguan Ganfeng	79.61%
Ganfeng New Lithium Source	93.09%

Ganfeng Lithium Battery and its subsidiaries received a total of approximately

in guarantees from the parent company, indicating significant financial pressure.

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Aspect	Impact Degree	Description
Spin-Off Listing	Completely Blocked	Cannot list within the 36-month administrative penalty restriction period
VAM Repurchase	Actually Triggered	RMB 1.6 billion repurchase completed, 23 institutions exited
Refinancing Capacity	Significantly Weakened	Administrative penalty and criminal filing affect capital market trust
Corporate Governance	Negative Impact	Unit crime determination combined with executive criminal liability risks

1. Stock Price Pressure
   : On the day of the announcement on December 29, 2025, the stock price fell by 4.74%, with a market value evaporation of over
   RMB 200 billion
   from its peak
2. Strategic Adjustment
   : Ganfeng Lithium Battery, as a key layout for closing the lithium battery manufacturing industry chain, has been forced to be shelved
3. Industry Cycle Overlap
   : The overall downturn in the lithium battery industry and compliance risks form dual pressures

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1. Legal Aspect
   : According to the “Rules on Spin-Off Listing of Listed Companies”, the 36-month restriction period resulting from Ganfeng Lithium’s 2024 administrative penalty directly blocks Ganfeng Lithium Battery’s independent listing path before July 2027
2. Capital Aspect
   : The VAM period expired on December 31, 2025. Ganfeng Lithium has responded through a RMB 1.6 billion repurchase plan, with 23 strategic investors exiting, and the spin-off listing plan has
   virtually stalled
3. Corporate Aspect
   : Although Ganfeng Lithium claims that the insider trading case is a “specific historical event” that does not affect normal operations, the advancement of criminal accountability and the high asset-liability ratio of its subsidiary indicate that it is facing significant operational pressure
4. Regulatory Signal
   : This case shows the regulatory authorities’ “zero tolerance” attitude towards insider trading, as they will advance criminal accountability even if the illegal gains do not meet the “huge amount standard”

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[1] Sina Finance - “From ‘Lithium King’ to ‘Involved Party’: Ganfeng Lithium’s Insider Trading Dilemma” (https://cj.sina.cn/articles/view/1393100891/5309085b00101g0mk)

[2] Caizhongshe - “Ganfeng Lithium Made RMB 1.10 Million from Insider Trading: Its Subsidiary’s IPO Is Affected, and It Spent RMB 1.6 Billion” (https://m.caizhongshe.cn/news-7540727959021214253.html)

[3] 36Kr - “The Nature of a 5-Year-Old Old Case Has Changed, Ganfeng Lithium Is in Trouble This Time” (https://m.36kr.com/p/3627764541682182)