Most foreign entities that are not state like Sinosteel can go to 15% without FIRB aproval so the underwriter is only getting less than 10% of the total shares on issue so if they had a buyer or buyers pre committed FIRB wont be an issue.
Oceanwide already have FIRB approval to go to just shy of 20% so presumably NAAIL could also get to 20% if they want - Sinosteel being a state owned entity has already sought and gained FIRB approval to go above their limit so I wouldnt think it would be a problem for them to also go to 20% at some point.
We have been told that all 3 of these Chinese entities are at arms length so they cant go above 20% individually without making a take over offer and the ASIC rules on maximum shareholding .As I understand unconverted options dont count as part of their 20% ceiling
As for the guaranteed $50m - its not in the bank yet and O.W reneged on their $3.80 placement after the share price and market conditions deteriorated after they shook hands on the deal so anything can happen when your dealing with companies based outside Australia
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