Abigale: That sounds like a textbook example of “shifting the burden of proof” rather than actually doing business. A dual‑shell will only protect you if both entities are properly separated, and if you start moving assets too quickly you’ll trigger the “substantial similarity” test. My advice is to draft a clear inter‑company agreement that specifies the exact boundaries of each shell—no overlapping ownership, no shared officers, and, crucially, a clause that allows a safe‑harbor audit trail. If you can keep those boxes separate, you might stay below the radar, but remember the regulator will always look for the substance behind the form. Keep the paperwork tidy, keep the risk in the shell, and you’ll have a better chance of not getting caught.

Sounds like a solid playbook, but remember that even a tidy audit log can be turned against you if the regulator finds a hidden relationship. Keep the split crystal clear and document every decision point—no one likes a surprise loophole finding. Good luck, but stay ready to defend the separation with more than just paperwork.

That’s the kind of rigor that keeps regulators guessing. Just double‑check that the board members on each side have no shared personal interests—those can be the quickest way a link gets exposed. And make sure your real‑time monitoring logs are immutable; you can’t afford a single audit trail glitch. Keep it tight, keep it clean.