年报重大遗漏，三七互娱及高管被罚3200多万

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has issued a notice of administrative penalty to Sanqi Interactive Entertainment Network Technology Group Co., Ltd. and its key personnel for violations related to false disclosures and undisclosed related party transactions in their annual reports from 2014 to 2021 [1][2][3]. Group 1: False Shareholding Disclosures - From 2014 to 2020, the annual reports of Sanqi Interactive contained false records regarding shareholder holdings, specifically concerning shares held on behalf of key executives [1][2]. - The shareholding arrangements were decided by key executives, with all funds for the shares coming from their equity acquisition payments [2]. - The CSRC believes these actions violate multiple provisions of the Securities Law, constituting illegal behavior [2][3]. Group 2: Undisclosed Related Party Transactions - In the 2018 annual report, Sanqi Interactive failed to disclose the acquisition of a 20% stake in Jiangsu Jiguang as a related party transaction, which was a significant omission [4][5]. - The CSRC identified that the transaction involved a related party, as the individual from whom the stake was acquired had a special relationship with the company [5]. - Similar omissions were found in the 2020 annual report regarding an indirect acquisition of Guangzhou Sanqi, which was also classified as a related party transaction [6][8]. Group 3: Undisclosed Transactions with Hainan Liyuan - Between 2018 and 2021, Sanqi Interactive did not disclose related party transactions with Hainan Liyuan and other companies, amounting to significant sums in each year [9]. - The CSRC noted that these transactions were not reported in the annual reports, constituting major omissions [9]. Group 4: Penalties Imposed - The CSRC plans to impose a fine of 9 million yuan on Sanqi Interactive and additional fines on key personnel, including 14 million yuan on Li Wei, the actual controller [9][10]. - Other executives involved will also face fines ranging from 80,000 yuan to 1.4 million yuan depending on their level of responsibility [9][10].