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BTCI does hold 40% of the Member Units of Coin Services LLC. This amount of units is the basis of the investment on Havelock for foreign investors. US investors will invest directly with the US LLC via a Reg. D 506c exemption we have obtained from the SEC. To avail ourselves of both exemptions we do need to keep the two offerings separate from each other and will do such through the onshore and offshore entities. ...
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.
You might be misunderstanding that this IPO is for BTCI, rather than CS LLC. If you want to invest directly with CS LLC then you must be accredited and find other means, to which, I'm not sure what offerings, if any, are available. CS LLC is not seeking direct funds from Havelock, so what Havelock does or doesn't have to facilitate the SEC doesn't matter.