Core Viewpoint - The article highlights the long-term misconduct of Sanqi Interactive Entertainment, revealing systematic concealment of shareholder representation and undisclosed related-party transactions over seven years, leading to significant penalties from regulatory authorities [1][2][5]. Summary by Sections Regulatory Actions - On October 31, 2025, the China Securities Regulatory Commission (CSRC) issued a notice of administrative penalties against Sanqi Interactive Entertainment, imposing a fine of 32.55 million yuan for various violations [1][6]. - The penalties included warnings and fines for key executives, with the chairman facing a total fine of 14 million yuan, including direct responsibility [7]. Misconduct Details - The company engaged in shareholder representation concealment since 2014, where shares were held on behalf of the chairman and vice-chairman, leading to false disclosures in annual reports [3]. - Significant undisclosed related-party transactions were identified, including a 1.176 billion yuan total from 2018 to 2021, involving transactions with entities controlled by the chairman and vice-chairman [4][8]. Financial Performance and Challenges - Sanqi Interactive Entertainment has faced stagnant revenue growth, with a compound annual growth rate (CAGR) of only 5.1% from 2020 to 2024, and a 6.6% year-on-year decline in revenue for the first three quarters of 2025 [10]. - The company's gross profit margin has decreased by 9.2 percentage points over five years, reflecting rising customer acquisition costs and pressure from IP revenue sharing [10]. - The company’s R&D expense ratio is notably low at 4.1%, compared to competitors like Jiubite at 23.6%, indicating a lack of investment in original IP development [11]. Market Position and Strategy - Sanqi Interactive Entertainment relies heavily on external IP adaptations, with its self-developed IP underperforming in revenue generation [11]. - The company’s high customer acquisition cost, at 49.8%, raises concerns about its competitive position in the market, especially compared to peers [11]. - The overseas revenue contribution is only 32.1%, which is lower than competitors, indicating limited international market penetration [11]. Governance and Long-term Implications - The article suggests that the company's reliance on shortcuts, such as concealing shareholder structures and related-party transactions, has led to governance issues and long-term business challenges [12][13]. - The regulatory scrutiny and market conditions may expose the hidden costs of these practices, potentially impacting investor trust and future financing opportunities [8][12].
三七互娱的“隐秘角落”:七年暗箱、数十亿隐账与一场迟到的审判