Credit: Investopedia / Sydney Burns
前言：如果你讀過經濟學，知道什麼是套戥 (Arbitrage) （意思：同一貨物或資產在不同國家之間存在價格差異，形成低買高賣的套利空間），監管套利（Regulatory Arbitrage）這個概念應該難不到你。
監管套利（Regulatory Arbitrage）（另一寫法：合規套利 Compliance Arbitrage）的意思，是利用監管制度之間的差異，無風險地降低（合規）成本、謀利（爭取最大利潤）、節省（走程序所需要的）時間。那些監管制度上的差異，可以是存在於不同國家（或司法管轄區）之間，英文叫 cross-country arbitrage or cross-jurisdiction arbitrage （例如：開設離岸公司隱藏資產，改變上市公司的註冊地點），也可以是存在於同一國家的不同行業之間（例如：銀行 vs 證券），英文叫 cross-sector arbitrage。常見的操作，是從一個監管嚴格的國家或行業轉移至另一個監管嚴格比較寬鬆的國家或行業，又或者從現實世界轉移到虛擬世界（提示：比特幣）。
這種做法（在監管制度之間鑽空子以及套利）是合法的，但是未必符合道德，監管機構也有辦法應付。監管套利的存在，迫使法規和制度不斷完善，但是也可能導致系統性風險 (Systematic Risk) （例如：被銀行轉移至資產負債表以外的投資產品全線崩盆導致銀行業發生重大危機），是一把雙刃劍 (Double-edged sword)。
金錢無國界，監管套利（Regulatory Arbitrage）在不講道德的金融業很常見，而跨國企業 (Multi-National Corporation, MNC) 在處理國際貿易或直接投資或日常營運層面也會用上。例如：Transfer Pricing 是把跨國企業在某個國家的合法利潤轉移至低稅率的地區，而美資科網巨企的熱門選擇是愛爾蘭。
另外，由於監管套利常用的操作方法經常被壞人用來隱藏資產或漂白犯罪收入，從事反洗錢 (Anti-Money Laundering, AML) 工作的人也會對這一套有認識。請參考 Anna Stylianou 的貼文，她的說法簡而清。常見的監管套利：中國大陸有外匯管制而香港沒有，於是香港成為大陸人走資及洗黑錢的地方。香港是鹹淡水交界（提示：一國兩制），特別多監管套利活動，而走資及洗黑錢，還有走私及逃稅等活動背後的思路，是在不同的制度之間鑽空子及套利。對香港人來說，是家常便飯，見慣見熟。中文財經媒體不敢深入討論，背後是什麼原因，你懂的。
以下提供的參考資料，從不同角度解釋或討論監管套利（Regulatory Arbitrage）這個概念。學會了監管套利（Regulatory Arbitrage）這個概念，以及常用的操作方法，你會讀懂很多財經新聞 （例如：加密貨幣到底是金融創新還是監管套利？），也會明白一些常見的金融或商業罪案背後的邏輯（壞人的思路和手段），以及監管機構可以怎樣回應。
Anna Stylianou 的貼文
Regulatory Arbitrage
Maybe you’ve heard the term, maybe not.
But if you work in AML, you’ve probably seen it.
Regulatory arbitrage means exploiting differences or loopholes in regulations across countries or sectors.
They do this by:
- Choosing jurisdictions with weak or lighter AML supervision
- Using offshore companies with limited transparency
- Moving money through products that fall outside the regulated sector
Why do people do this?
To gain a financial advantage, reduce costs or avoid stricter rules without technically breaking the law.
It’s common in finance. Especially in setups involving banks, hedge funds, and cross-border transactions.
And while it’s often legal, it creates real exposure.
Regulatory arbitrage is also used by bad actors to hide the proceeds of crime.
It’s a method often exploited by sanctioned persons and networks that rely on weak oversight to move money undetected.
For example:
- A client may set up an offshore entity to access international markets or manage tax exposure - which is legal.
- But the same setup could also be used to obscure the illegal source of funds, hide beneficial ownership, or bypass sanctions.
On the surface, the structure might look the same.
But the intent behind it - and how it's used - makes all the difference.
It’s important to understand this behaviour, because regulatory arbitrage is used for both legal and illegal purposes.
That’s why this behaviour needs to be understood.
Because when it’s used to hide something, you won’t find it by ticking boxes.
You’ll find it by going deeper.
What’s your view?
（推介原因：簡而清。作者是金融罪案專家，熟悉反洗錢法規。）
Investopedia
Regulatory Arbitrage: What It Means and Examples
By Adam Hayes
Updated June 29, 2021
https://www.investopedia.com/terms/r/regulatory-arbitrage.asp
Excerpt: What Is Regulatory Arbitrage?
Regulatory arbitrage is a practice whereby firms capitalize on loopholes in regulatory systems in order to circumvent unfavorable regulations. Arbitrage opportunities may be accomplished by a variety of tactics, including restructuring transactions, financial engineering, and geographic relocation to amenable jurisdictions.
Regulatory arbitrage is difficult to prevent entirely, but its prevalence can be limited by closing the most obvious loopholes and thus increasing the costs associated with circumventing the regulation.
Key Points:
- Regulatory arbitrage is a corporate practice of utilizing more favorable laws in one jurisdiction to circumvent less favorable regulation elsewhere.
- This practice is often legal as it takes advantage of existing loopholes; however, it is often considered unethical.
- Closing loopholes and enforcing regulatory regimes across national borders can help reduce the prevalence of regulatory arbitrage.
How Regulatory Arbitrage Works
Businesses might apply regulatory arbitrage strategies to take advantage of tax havens and other forms of regulatory breaks. This can be accomplished by incorporating the company or establishing subsidiaries in jurisdictions that offer regulatory advantages.
For instance, the Cayman Islands are frequently chosen as the relocation destination for companies applying regulatory arbitrage. The government of the Cayman Islands allows businesses to form there and not pay taxes on revenue earned outside of the territory.
Rather than pay taxes, companies located there pay a licensing fee to the local government. Similarly, in the United States, many companies choose to incorporate in the state of Delaware due to its more favorable taxation and regulatory environment.
While regulatory arbitrage is often legal, it may not be entirely ethical as the practice can undermine the spirit of a law or regulation, which can lead to potentially harmful consequences. For instance, if a country has lax regulations on money laundering, a corporate unit located in that country could exploit that to conduct malfeasance.
Enticing Regulatory Arbitrage
Reduced regulatory burdens and increased privacy on executive income have made such havens attractive to banks in particular. Economic crises in the United States triggered the introduction of legislation to bolster the regulation of the financial industry. The heightened burden faced by these banks led to regular arbitrage efforts.
For example, banks might look to cross-border acquisition deals in order to create an avenue to essentially escape the regulatory systems they are under. By acquiring an institution in a more favorable regulatory environment, the bank might be able to remove itself from oversight deemed burdensome.
There are locations within the United States that offer certain tax breaks. There is no state sales tax for example in Delaware. State corporate income tax on goods has also been eliminated in that state.
Businesses incorporated in Delaware do not need to have their operating headquarters located there to benefit from the tax breaks or other advantages. For example, a company could establish a subsidiary office in the state to meet the criteria needed to benefit from the regulatory breaks the state offers.
Companies can also structure transactions to their advantage. An example of regulatory arbitrage came from Blackstone's 2007 IPO. In an unusual move, Blackstone went public as a master limited partnership in an effort to avoid the higher tax rates imposed on corporations. In order to retain these tax advantages, Blackstone also had to avoid classification as an investment company. Through carefully negotiating the tax regulations, Blackstone sought to exploit a "regulatory arbitrage" between the tax code's legal definitions and economic substance.
（推介原因：「監管套利」的定義。Investopedia 是值得推介的網上財經術語辭典。）
European Central Bank
Gaming the rules or ruling the game? – How to deal
with regulatory arbitrage
Speech by Danièle Nouy, Chair of the Supervisory Board
of the ECB, at the 33rd SUERF Colloquium, Helsinki, 15 September 2017
https://www.bankingsupervision.europa.eu/press/speeches/date/2017/html/ssm.sp170915.en.html
Excerpt: It is true that banks can be highly innovative when it comes to reducing the regulatory burden. They are always tempted to game the rules. They are tempted to exploit loopholes and seize on the fact that rules differ across countries and sectors.
Such regulatory arbitrage is, of course, a problem. Rules are put in place for a reason, and working around them defeats that purpose. As you all know, we have just emerged from the worst financial crisis since the Great Depression. That’s why we have made these rules stronger: to make such crises less likely. Whenever a bank tries to get around the rules, it increases the risk of another crisis.
So regulatory arbitrage is a matter of great concern for regulators and supervisors. Let’s take a closer look at how it works and what we can do about it.
What exactly do we mean by “regulatory arbitrage”? Well, we are referring to banks structuring their activities in a way that reduces the impact of regulation without a corresponding reduction in the underlying risk. The result, of course, is that the risk becomes insufficiently regulated. And that is not a good thing.
In very general terms, regulatory arbitrage takes three forms. The first can be described as “cross-jurisdiction arbitrage”. This exploits the fact that rules for banks differ from one country to another. Some rules, for example, might be less strict in country A, while others might be less strict in country B.
Banks might therefore be tempted to set up their operations in such a way that they are always subject to the most relaxed rules. They would constantly jump fences in order to be where the grass is greenest.
What is more, cross-jurisdiction arbitrage can also trigger a race to the bottom. Countries that lose business might be tempted to relax their rules as well in order to keep banks from jumping the fence. As a result, rules would become less strict around the world and crises would become more likely.
Here in Europe, cross-jurisdiction arbitrage has become even more of an issue since the United Kingdom decided to leave the EU. Post-Brexit, UK banks will need to set up entities in Europe, and most likely in the euro area, in order to retain access to the Single Market. In this context, we will need to keep a close eye on back‑to‑back booking, for instance.
However, jumping national fences is just one way to get around the rules. Banks can also jump sectoral fences. While the banking sector is highly regulated, other parts of the financial system are much less so. The shadow banking sector, for instance. This opens the door to what could be referred to as “cross-framework arbitrage”.
Banks can pass through that door by moving business to the shadow banking sector. They can shift exposures to entities that are not consolidated for prudential purposes. Looking back at the run-up to the financial crisis, one of the more popular ways to do this was through special-purpose vehicles, or SPVs. The consequences of this are now well known.
However, banks don’t need to turn to shadow banks. They also have other options when it comes to shifting business out of the prudential perimeter. These options often involve adjusting their legal structure. Under some accounting rules, for instance, joint ventures do not need to be fully consolidated. This allows risks to be kept out of regulators’ reach.
The danger, of course, is that these risks could eventually spill back into the banking sector. Out of the shadows, banks could suddenly be hit by a flood of risks that have not been accounted for.
This is what happened during the financial crisis. In the build-up to the crisis, banks shifted assets to SPVs (Special Purpose Vehicles). When those SPVs got into trouble and lost access to market funding, the banks stepped in. In many cases, they were not legally obliged to do so, but they supported the SPVs to safeguard their own reputations.
If banks shift exposures to shadow banks, they become vulnerable to what is known as “step-in risk”. And this kind of risk often remains hidden and unaccounted for. That’s why the shadow banking sector is a concern for banking supervisors. It is intertwined with the banking sector, and risks could easily spill over.
And finally, there is also a third kind of regulatory arbitrage, where banks do not even have to jump national or sectoral fences to find a way around the rules. This can be termed “intra-framework arbitrage”. In this case, rather than trying to exploit differences between two or more sets of rules, banks try to exploit loopholes within a single set of rules.
Banks’ main objective in this regard is to “optimise” prudential indicators such as capital and liquidity ratios. To call a spade a spade, they seek to hold less capital and liquidity for a given level of risk. In order to achieve this goal, they have to structure transactions in such a way that the underlying risk profile remains unchanged, but the amount of capital or liquidity that needs to be held is reduced.
This affects the leverage ratio and the liquidity coverage ratio, for instance. Two things can be observed in this regard. First, although the rules do capture most off-balance-sheet exposures, they still leave some room for interpretation. So banks have an incentive to move exposures off their balance sheets to make use of this grey area.
Second, there is scope for banks to tweak the maturity of transactions – particularly where the contractual and economic maturities of a trade differ. As regards the leverage ratio, for instance, more capital needs to be held for longer-dated derivatives than for shorter-dated ones. At the same time, the liquidity coverage ratio only captures transactions with a residual maturity of 30 days. This might tempt banks to structure their transactions around certain maturity thresholds to save on capital and liquidity.
To sum up, banks have plenty of scope for getting around the rules. And this is a problem. Regulatory arbitrage undermines the basic idea of regulation, and it poses a threat to stability. So, the question is: what do we do about it?
The regulatory and supervisory response
Well, regulatory arbitrage often exploits differences between rulebooks. So, the first thing we can do is harmonise the rules. This is a powerful tool when it comes to preventing cross-jurisdiction arbitrage, for instance. If the rules were the same in all countries, banks would have less scope for getting around them.
Here in Europe, we are in a similar situation. For some time now, we have had a single European rulebook for banks. However, parts of that rulebook still need to be transposed into national law. And this has, again, led to differences in rules across countries. As I said earlier, the single European rulebook is not yet single enough. There are still differences that banks can exploit – something that has gained even more relevance with Brexit on the horizon.
So, there is a clear case for further harmonising the European rulebook. To that end, we should rely less on EU directives and more on EU regulations, which are directly applicable in all Member States.
However, as I said earlier, it is not just about differences between countries. There is also the issue of cross-framework arbitrage and the shadow banking sector.
From my point of view, the first priority is to try to ensure that no risks spill over from the shadow banking sector to the banking sector. This means looking at the links between banks and shadow banks and addressing step-in risk.
From a supervisor’s point of view, it is important to tackle the links between banks and shadow banks. But shadow banking raises other, broader issues as well. Against that backdrop, I fully support the work being carried out by the G20 and the European Commission. The aim should be to address financial stability concerns and turn shadow banks into a resilient source of market-based funding.
This brings us to the third form of regulatory arbitrage: the one that happens within a single set of rules – intra-framework arbitrage. Here, we are more concerned with closing loopholes rather than harmonising rules and preventing the spillover of risks. This can be achieved using a variety of different tools.
One solution could be to change the rules in such a way that loopholes are closed. However, for this to be effective, regulators would first have to identify every loophole, which we all know is impossible. So it makes sense to also apply tools that have a broader and more preventive effect. And such measures are indeed being implemented.
But tackling regulatory arbitrage is about more than just multidimensional rulebooks. It’s also about flexibility. As former Deputy Governor of the Bank of England Paul Tucker writes: “A static rulebook is the meat and drink of regulatory arbitrage.”
The more detailed the rules are, the more scope there is for getting around them. Rules should therefore be based on key principles. “Same business, same risk, same rules” is one of them. Shaping the rules in line with this principle would help to further limit opportunities for regulatory arbitrage.
To sum up, there are ways and means of dealing with regulatory arbitrage. These range from harmonising rules across countries to closing loopholes. But in spite of all that, regulatory arbitrage will remain an issue.
The financial crisis triggered an overhaul of banking regulation, and banks now face much tougher rules than ever before. This is good, of course. Still, it gives the banks even more incentive to game the rules. This is reinforced by the fact that competition among banks is very intense. They might therefore try to gain a competitive edge by getting around the rules and avoiding the associated costs.
Against that backdrop, supervisors need to keep a close eye on banks. Prudential banking supervision is fundamentally about ensuring sensible bankers set aside enough capital for the risks they choose to take. Supervisors do this in a number of ways but the end result should always be the same: well capitalised banks that take prudent risks. For euro area banking supervision, an important element of this is ensuring supervisors can have confidence in the internal models used by some banks to calculate risk and the level of capital they need to set against it. The ECB’s ongoing targeted review of internal models at over 60 banks, including all eight of the globally significant banks supervised in the euro area, is an important part of this process.
Supervisors need to scrutinise what bankers do and examine individual transactions to see whether they might be an attempt to game the rules.
Conclusion
I think we can all agree that an unregulated banking sector is not a good thing. Experience – some of it fairly recent – shows that banks need rules. Effective rules help to ensure that banks remain resilient and can reliably serve the economy.
It is true, of course, that rules also place a burden on banks. Complying with them is costly. As a result, banks are always tempted to work around rules, particularly in difficult times such as these.
Such behaviour may look optimal from the point of view of an individual bank. But from the perspective of society as a whole, it is not. Working around the rules undermines their purpose and might lead to another crisis. And we all know what such crises entail for the economy, for savers, for investors and for taxpayers.
So, regulators and supervisors are engaged in a game of catch-up with banks – a game that is sometimes referred to as “regulatory dialectic”. Regulators set rules in order to ensure stability and prevent financial crises. Banks seek ways around these rules in order to lessen the associated burden. Regulators then adjust the rules; and banks find new ways to get around them. This game has probably been going on since the very first rule was designed – and not just in banking, either. And it will probably go on until the end of time.
So it is in everyone’s interests for supervisors and regulators to have the edge in this game. They have to rule the game, in order to prevent banks from gaming the rules.
（推介原因：這篇講稿以歐洲銀行業為例子，陳述金融監管機構的觀點及回應方法。法規是用來預防金融危機，但是銀行業競爭激烈，為了節省成本，銀行會想辦法在監管制度之間或法規之內尋找漏洞，然後監管機構填補漏洞及修改法規。過了一段日子，銀行業想出新的方法繞過法規，監管機構知道之後，變陣回應。貓捉老鼠，沒完沒了，就是這樣。 ）
Investopedia
Systematic Risk: Definition and Examples
By James Chen
Updated July 01, 2025
https://www.investopedia.com/terms/s/systematicrisk.asp
Definition: Systematic risk can arise from factors such as inflation, recessions, changes in interest rates, and other macroeconomic events that impact the overall market.
What Is Systematic Risk?
Systematic risk is unpredictable and impossible to completely avoid. It's also known as undiversifiable risk, volatility risk, or market risk. It’s the result of macroeconomic events that affect the market as a whole and cannot be controlled, at least by an investor. The Great Recession is a primary example. Investors can adjust their portfolios accordingly, however.
Key Points:
- Systematic risk reflects the impact of economic, geopolitical, and financial factors.
- This type of risk is distinguished from unsystematic risk which impacts a specific industry or security.
- Systematic risk is largely unpredictable and is generally viewed as being difficult to avoid.
- Investors can mitigate the impact of systematic risk somewhat by building a diversified portfolio.
（推介原因：系統性風險 (Systematic Risk) 的定義，Investopedia 是值得推介的網上財經術語辭典。）
法規套利 (Regulatory arbitrage)
新聞參考資料 (金融監理法規之新興議題)
中華民國中央銀行全球資訊網
Central Bank of the Republic of China (Taiwan)
發布日期：2003-09-03
https://www.cbc.gov.tw/tw/cp-432-20505-BAFA6-1.html
節錄：國際貨幣基金 (IMF) 於 2003 年 5 月發布「金融監理法規之新興議題」(Emerging Issues in Banking Regulation) 工作報告，該文檢視科技及金融創新對金融體系及金融政策之影響，說明金融監理法規之演進及新巴賽爾資本協定之內涵，並探討新金融監理架構在開發中國家實施所面臨之挑戰。
由於科技進步及金融創新，使金融機構間界線越趨模糊，加速金融合併，並促成規範金融機構差異性之法規鬆綁。銀行面臨日益競爭環境將可能冒著更高風險，使金融監理制度面臨四大挑戰：
1. 須修訂以風險為基礎之資本規範，以精確反映金融機構真正承擔之風險；
2. 金融機構資產負債表內容快速及複雜之變化，已使傳統資本規範不適作為監理工具；金融監理重心將由資本規範，轉為重視金融機構內部風險管理評估及市場制約機能；
3. 金融商品間及金融機構間差異之模糊化，需要一套兼顧市場效率及金融穩定之公平競爭規則，以避免發生法規套利 (regulatory arbitrage)；
4. 監理法規架構及監理制度應設計避免大型金融機構產生道德危險(moral hazard)，並發展提供金融安全網之新方法。
（推介原因：金融監管機構的角度。）
金融科技的高估值：
是科技創新還是監管套利（Regulatory Arbitrage）？
2020 年 11 月 11 日
https://www.usfsr.com/blog/regulatory-arbitrage
節錄：金融科技的獲利是科技創新、還是只是監管套利?
傳統金融面臨大量法規監管的成本跟限制。這些規定有些沒什麼道理、但有些還是維繫著基本的銀行運作，包括資本適足率、信用管制等等。
如果要說天花這種疾病因為疫苗絕跡，那在金融則是"銀行擠兌"這件事情在現代監管下也幾乎絕跡。
台灣 2000 年前經常有銀行倒閉、存戶擠兌的情況。但現代的銀行即便在低利率、疫情下，大家也只搶衛生紙、不會到銀行搶現金。
另外，金融海嘯最核心起源被認為是來自 Credit Misallocation。而之後延伸的各種管制，即便在COVID期間，市場也鮮少出現大規模的金融損失。
而在今天，金融科技可以直接繞過這一切的管制。像在台灣，如果因為DBR22倍無法從銀行取得貸款，有各種金融科技P2P Lending 可以讓你拿到更多貸款。
當然，不能說完全沒有科技創新的成分在，但也不能說沒有監管套利 (Regulatory
Arbitrage) 的成分在。因此有了一系列的研究在這爭議的問題上。
彭博專欄作家：「監管套利」正是加密貨幣優勢，迫使陳舊法規迭代更新
Jim
2022/7/27
https://abmedia.io/20220727-crypto-is-a-form-of-regulatory-arbitrage
節錄：加密貨幣最常見的批評無非是它能規避大量現有法規，但彭博社專欄作家 Tyler Cowen
指出，這與許多新創相同，「監管套利」是加密貨幣的特徵，而不是一種過錯，同時也傳達了陳舊法規需要改變的訊息。
相關的文章：
套戥
2014 年 4 月 26 日
https://xiaoshousha.blogspot.com/2014/04/blog-post_26.html
節錄：教科書的說法：套戥 (Arbitrage) 是透過同一（或類似）資產於不同市場的價格差異獲利。方法：在其中一個市場購進或借入資產，然後在另一個市場沽售或拆放。理論上，套戥活動會令價格差異收窄（至接近交易成本的水平），甚至是完全消失。而最常見的套戥行為，是透過價格、利率或匯率的差異來賺錢。例如：
數碼貨幣 (Part 4)
2021 年 7 月 3 日
https://xiaoshousha.blogspot.com/2021/07/blog-post.html
節錄：科技發展通常領先於監管制度，當科技開拓出一片新的空間，又或者是各國的法律（暫時）管不到的灰色地帶，就會吸引一大群烏合之眾、失業中年、異族浪人或鬼魅魍魎湧入去，趁亂謀取私利、搶佔市場、建立名氣（稍後套現）、清洗黑錢、累積跟官府談判的籌碼，諸如此類。區塊鏈或虛擬貨幣亦可作如是觀，趁入行門鑑 (Entry barriers) 還沒有升高，遊戲規則還未定形，監管機構還沒有找到適當的應對方法，盡快把事情扭曲成最符合自己利益的樣子，否則來不及。
Kleptocracy（盜賊統治）
2021 年 8 月 20 日
https://xiaoshousha.blogspot.com/2021/08/kleptocracy.html
節錄：盜賊統治 (Kleptocracy) 跟洗黑錢活動關係密切，有如連體嬰，或錢幣的兩面。Kleptocrats 是指貪污腐敗的當權者（竊國者），這個詞經常在英語傳媒對於洗黑錢活動的調查報導中出現。金錢無國界，竊國者透過離岸公司及複雜的股權結構，把不義之財轉移至對資產提供較佳保障的西方國家，然後隱藏起來。竊國者要保護自己的權力以及家族利益，必定會全力摧毀本國的法治及設法打壓公民社會，同一時間卻享受著西方國家所提供的法律保障，卑鄙無恥，對不對？
Pandora Papers
2021 年 10 月 4 日
https://xiaoshousha.blogspot.com/2021/10/pandora-papers.html
ICIJ links for readers interested in offshore finance:
諜影
2016 年 4 月 22 日
http://xiaoshousha.blogspot.hk/2016/04/blog-post_22.html
節錄：根據 Washington Post 的報導，負責分析文件的國際調查記者聯盟 (The International Consortium of Investigative Journalists, ICIJ) 背後的美國公共誠信中心 (Center for Public Integrity)，金主是國際大鱷索羅斯 (George Soros)。他較早前表示會「沽空亞洲貨幣」，令偉大祖國非常緊張，官媒輪流開炮。索羅斯戰績彪炳，利用在金融市場賺來的錢，資助共產黨的對頭人。中國和俄羅斯的領導人首當其衝，被爆陰毒，理所當然。
隱身術
2019 年 9 月 27 日
https://xiaoshousha.blogspot.com/2019/09/blog-post_27.html
節錄：早於 2018 年初中美貿易戰爆發之前，紅色資本的海外併購活動已經遇到困難。西方國家基於國家安全考慮，對中資說不（提示：倫敦交易所），又或者設置障礙。中資的回應方式，是動用港人、台商、南洋華僑甚至親共洋人 (Panda Hugger) 當人頭或 Frontman，讓大股東可以退居幕後。
雙軌制（二）
2011 年 10 月 28 日
http://xiaoshousha.blogspot.hk/2011/10/blog-post_28.html
節錄：跟前輩學會的第一個具備中國特色的財經術語，叫「假洋鬼子」，意思是大陸的個人（通常持有香港身份證或者外國護照）或者企業於境外成立離岸公司 (Offshore company)，然後以「外資」的身份回大陸投資，目的是享受稅務優惠，又或者從事某些不正當的業務，例如：虛假交易、虧空公款、轉移資產、洗黑錢、套匯、套息、套戥（利用匯率、利率和價格差異圖利），駐港中資機構尤其精於此道。
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