While we're jumping on the facts bandwagon, I do want to take the opportunity to address this:
"The substantial holder notice requirements are a joke and are not enforced."
The requirements are not a joke and they are enforced. People have been jailed for non-compliance:
https://www.herbertsmithfreehills.com/insights/2020-02/no-more-hiding-asic-pursues-criminal-charges-for-defective-disclosure-of-substantial
Jan Cameron was convicted nearly 10 years after the offence:
https://asic.gov.au/about-asic/news-centre/find-a-media-release/2023-releases/23-341mr-janet-cameron-found-guilty-of-not-disclosing-her-interest-in-bellamy-s-australia/
Subject to any appeals, she is now automatically disqualified from managing a corporation for five years.
So the facts are:
- Substantial holder notice requirement are enforced
- Notice requirements are not a joke (unless you consider fines, disqualifications and jail time as a joke)
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