Nope...wrong interpretation. AMFN already reduced both the OS and AS. They are also talking about a possible stock dividend. AMFN is NOT obligated to do a reverse split of any magnitude. What's in the Form 10 is "boilerplate" language.
You assume penalties that are not there and assume what's a penalty and what isn't. Its up to the SEC to determine if AMFN or any company breaks or violates rules. They don't just magically show up because of a particular interpretation.
Yes...everyone should do their own due diligence and research. Stay away from biased sources that want you to believe a particular narrative.