The forex regulator keeps easing settlement for offshore entrepot trades - goods that never enter the mainland while a domestic firm runs back-to-back buys and sells. Qualifying firms can net settle and process with electronic documents, keeping funds off onshore accounts.

This fits SNSUC's crude transshipment directly: buy ESPO or Dubai from a supplier, resell to a third country, with title changing hands offshore and settlement in cross-border CNY or offshore USD - no spot conversion and no FX exposure.

Compliance hinges on a closed document chain: sales contract, bill of lading, warehouse receipt and invoice must agree across three flows. Digital receipts with SHA-256 notarization let regulators and banks verify 'real title' in seconds, lowering the odds of being misread as a constructed trade.

On stamp duty: instruments for offshore entrepot transfers are exempt or reduced under the property-transfer schedule depending on structure, so the paperwork cost on a large transshipment is far below ordinary trade.