In response to the announcement of Kushim <2345> on November 25 regarding the resolution of the recommendation for the resignation of one director and the establishment of an internal investigation committee, discussions on the Wolf Pack strategy have reignited.

The Wolf Pack strategy is a method where individual shareholders who are secretly cooperating keep their ownership stake in the target company below 5%, in order to avoid the application of the large shareholding reporting system. If the large shareholding report is submitted, there is a possibility that the stock price will rise, so the purpose is to delay the submission and continue buying the shares at a low price. Under the Financial Instruments and Exchange Act, jointly acquiring, transferring, or exercising voting rights over stocks is considered joint ownership, therefore intentionally avoiding the submission of large shareholding reports could be deemed illegal.

According to Kushim's press release, it was confirmed that there were statements indicating that important information of Kushim shared between A, a recipient of important facts, and Hiroki Tahara, a director of Kushim (hereinafter referred to as 'Tahara'), both directly and indirectly hold Kushim shares, and there was a proposal suggesting that Bitcoin could be brought into Zaif, a consolidated subsidiary of Kushim, from mainland China. If this is true, it raises suspicions of insider trading, and if the direct or indirect shareholding in Kushim exceeds 5%, there is a possibility that the Wolf Pack strategy is being implemented, leading to reignited discussions.

The illegal Wolf Pack strategy, commonly used by Chinese capital groups, has been reported in multiple cases in the past. Taking advantage of the light penalties in Japan's Financial Instruments and Exchange Act, there are concerns about deliberately engaging in illegal activities.

Furthermore, another point of contention is the proposal to bring Bitcoin from mainland China, which is also accompanied by concerns about money laundering, and includes content that ignores the FATF (Financial Action Task Force) standards that domestic cryptocurrency exchanges should adhere to, posing a significant risk to Kushim's economic foundation and potentially leading to risks to national economic security. Kushim owns a subsidiary cryptocurrency exchange Zaif, and alongside concerns about money laundering, it is argued that if it involves the acquisition of an exchange, it could also evolve into an issue of Japan's economic security.

The system for reviewing and regulating investments from foreign countries is well-known in the United States as CFIUS (Committee on Foreign Investment in the United States). With increasing geopolitical risks, there is a need for the establishment of a Japanese version of CFIUS, and the issue involving Kushim this time can be considered a case that highlights various problems.