Non US parties are not required to comply with 13D,or filings as control persons
Someone pointed out that "Granted, it is difficult to find anything on the 13D, but it is very easy to find info on Form 4. Form 4 is required to be filed by anyone (no exclusions mentioned in any info about this form), who owns 10% or more of a company's stock (that includes individuals or organizations). Once that entity owns 10%, any trades (buys or sells) that affects that entity's holdings must be reported using a Form 4, at least until the entity's holdings falls below the 10% threshold."
The structure used by large holders is to break up their holdings into many, many names, thereby circumventing Form 4 issues.
This is a very common structure for major offshore investors, multiple jurisdicitons, in multiple forms of holding structures, sometimes with multiple different beneficial interest holders. It depends on their countries' tax rules, and the advise they get from their lawyers, executors and trustees.
It is a form of diversification of sovereign risk, and is conservative financially.
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