I think if they are smart they easily could get their holding up to 19.99% whilst keeping the price under 10 cents.
Whats to stop them doing a deal with Pattisons, UBS and credit suisse to get them to each buy 2.5% of the shares on the market then sell them to Huayou off market at a premium which is still below 10 cents.
For all we know these 3 companies may already hold the required shares for them.
At the same time Huayou buy 2.5% on the market and that way the only holding notice they will have to issue is the one saying they now hold 19.99%
AVZ Price at posting:
4.0¢ Sentiment: None Disclosure: Held