·         International expansion

·         ESOP launched

·         Secured varied funding

Governance gaps:

Governance gaps:

·         Accredited investor oversight

·         Fragmented ownership structure

·         Inadequate due diligence and record keeping

·         Regulatory compliance

·         Prioritize regulatory compliance.

·         Maintain accurate records.

·         Monitor shareholder composition.

·         Make sure strategic planning has a governance oversight.

Whilst I am not greatly familiar with start ups and private investing it is evident to avoid regulatory risks leading to the SEC or other security exchange intervening requires these start ups to work as if public listed but with a lower reporting burden. Some of the learning is around critical regulatory compliance such as accredited investors and engaging with shareholders similar to a public listed company. I would ask the question ‘what is the minimum we need to do if we were a publicly listed company and importantly what is the maximum we need to do as a start up, specifically around investor compliance.

The governance gaps included not screening investors as they should have, minimal record keeping and consulting with their investors which threatened SEC complaints and forcing public listing to early which risked takeover.

However, there were several governance gaps. The fragmented shareholder structure created by the equity restructuring resulted in a large number of individual shareholders, which would make shareholder engagement and annual general meetings more difficult to manage. There also appeared to be weaknesses in regulatory compliance processes and record-keeping, particularly in relation to verifying accredited investor status. Greater due diligence and oversight may have identified these risks before the restructuring occurred.