Lol, 506c, while allowing general solicitation, requires you to sell only to accredited investors.  Havelock has no mechanism in place even for basic AML, forget verifying investor qualification.  You've got to be either pretty desperate or astoundingly cocky to try this.


Nah, it's simply embarrassingly inept.  It's transparent what you wish to accomplish (trust me, you didn't invent HK/BVI/SA shells), the problem is the haplessly amateurish way you went about it.

Reading your prospectus, all I could think about was the hopeful cargo cultists building landing strips, replete with straw airplanes and even control towers, "to make other planes come."  Just like they've seen Americans do.
U no wat tho?
These Melanesian weren't clever enough to fool them big smart airplanes.  The planes of plenty never came.  Heartbreaking.

To be a bit more blunt:  To you your "prospectus" might seem not much different from the one you've started out with, but to others it's as convincing as a straw cargo plane.

BTW, these forums are a treasure trove of evidence to any TLA choosing to bother.  Talk about paper trail  

*So many gems I missed
Fun with words:  Declare HASH a religion.  Your investors are your disciples, your employees donate labor, in exchange you bless them with money, your warehouse--church property.  Thinkin' fellars like us, if we just put our heads together...  No telling what we could do!