No Jack, I don't think anything terribly ilegal has happened here, and you might read my posts further up this thread for better clarification.
Basically, instead of paying cash-up-front, for all of the placement, the recipient simply has a debt to CVI in respect of the shares that they have been allocated. SO they get them on credit, in effect. As they sell those shares on market that debt can then be extinguished.
Then using that money, the shares in Pensador can be bought, which effectively means the money goes into Pensador where it was supposed to go. Where it goes from there, I have no idea.
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