But being on either end it would seem to me that the holes would be to discourage cutting holes in the internal tube and using the fake can as a blast chamber. The definition of silencer is "reduces the report". The inside and outside tube design as pictured can be modified to reduce the report of the firearm. It doesn't have to reduce the report very much. An example would be the moderators for the early Colt M16 carbines. It is my understanding that the the moderators were used to lower the sound of the early Colt M16 carbines, which were used by US special forces, so that the Vetcong/North Vietnamese would not know that they were facing more highly trained troops. I have no documentation to back this up. The moderators do reduced the report of the carbines by two or three dBs. The ATF required that these moderators that were sold in the US be serialized and registered as silencers because of the reduction of the report.
It is my understanding that because of the possibility that a two tube design could easily be converted to reduce the report of the firearm, all of the modern "fake cans" that I have seen are made from solid stock, usually aluminum. The manufacturer that built the pictured fake can has long since gone out of business. ATF has not chosen to put resources into chasing down such products.
Scott