Okay this is what I did
1) Use Cl2 and H2O on ethylene to produce 2-Chloroethanol
2) Use 2-Chloroethanol with formaldehyde and a strong acid to get a hemiacetal
3) React the hemiacetal from above with ethylene and Cl2
On a side note:
Can you produce a hemiacetal using ethanol and then deprotonating it with NaH and then reacting it with the formaldehyde?