Critical Metals Corp
Critical Metals Corp is a BVI-incorporated, pre-revenue mining company seeking US government financing and a potential direct equity stake for rare earth extraction in Greenland, structured across multiple jurisdictions with connections to the US Commerce Secretary, former defense officials, and a pattern of serial share dilution and undisclosed officer legal history.
Critical Metals Corp (NASDAQ: CRML) is a British Virgin Islands-incorporated, pre-revenue mining company that holds the Tanbreez rare earth deposit in southern Greenland, the primary vehicle for US government-backed Greenland mineral extraction 1. Formed through a February 2024 SPAC merger with Cantor Fitzgerald as underwriter 2, CRML received a Letter of Interest from the US Export-Import Bank for up to $120 million in financing in June 2025 3, and as of March 2026, Trump administration officials have discussed taking a direct equity stake in the company 4. CRML reported losses of $51.9 million for fiscal year 2025 and $7.3 million in cash, with auditors citing substantial going-concern doubt 5.
The company is controlled by CEO Tony Sage through Australian parent European Lithium Ltd, which reduced its stake from 58.9% to 37.3% while extracting at least $54.75 million in secondary sales between June 2025 and February 2026 6. On November 25, 2025, CRML issued 2 million shares valued at $20 million to Swiss Commodity Re Limited for 40 kilograms of copper powder -- an asset priced at 100 to 2,500 times above verified market rates for equivalent or higher purity grades 78. The shares were immediately registered for resale with no lock-up period 9. CRML's SEC filings contain no disclosure of Sage's $9.36 million AFP confiscation order or $96 million ATO assessment, an omission that analysis identifies as a potential Item 401(f) violation 1011.
Howard Lutnick, the US Commerce Secretary, held an indirect interest in CRML through Cantor Fitzgerald's SPAC underwriting shares until May 2025 12. GreenMet, whose shareholders include former Trump Organization executive George Sorial, brokered the Tanbreez partnership but is absent from all 167 CRML SEC filings 13. On March 23, 2026, CRML acquired majority ownership of 60 North Greenland ApS, a Greenland logistics company, as the project enters operational preparation 14.
Swiss Commodity Re Copper Powder Transaction
On November 25, 2025, CRML entered an Asset Sale Agreement with Swiss Commodity Re Limited, purchasing 40 kilograms of copper powder claimed to be "ultra-high-purity" in exchange for 2 million ordinary shares valued at $20 million, or $10 per share 7. Swiss Commodity Re Limited is a Hong Kong-registered entity controlled by Kenneth Raymond Deayton, an Australian CPA whose professional background is in corporate services, company formation, and tax compliance, with no documented involvement in commodities trading or metals 1516. The press release described Swiss Commodity Re as "a long-only multi-generational European based single family office," a characterization contradicted by its Hong Kong registration and Deayton's corporate services background 16.
Market analysis from nine independent pricing sources established that the copper powder was priced at 100 to 2,500 times above verified rates for equivalent or higher purity grades 8. The comprehensive pricing ladder shows: Chemical Store lists 99.81% purity at approximately $110 per kilogram retail; Sigma-Aldrich catalogs 99.999% (5N) purity at $4.50 per gram; Alibaba bulk listings for 99.999% range from $4.50 to $23 per kilogram; and EU wholesale for 99.9999% (6N) purity ranges from EUR 250 to 385 per kilogram 8. At the most favorable lab-scale retail pricing for 99.999% material, the 40 kilograms would be worth $180,000; at realistic wholesale for 99.96% material, it would be worth $200 to $800 17.
CRML's press release simultaneously claimed 99.96% purity and "99.9999% or higher" purity for the same material 18. In industry terminology, 99.96% is sub-4N grade, below the purity of standard LME Grade A copper cathode (99.99%), and does not qualify as "ultra-high-purity" by any industry definition 1819. True ultrafine copper powder commanding EUR 300-2,500 per gram requires both sub-micron particle size and minimum 99.999% (5N) purity 19. The deal structure matches a documented commodity fraud pattern identified by Financely Group: fabricated valuations of $1,000-3,000 per gram are applied to copper powder using dubious certifications, then the material is used to justify share issuances or loan collateral 20.
CRML booked the copper powder at $15.8 million on its December 31, 2025 balance sheet as non-current inventory, not the $20 million announced price, with the equity statement showing shares valued at approximately $7.90 each -- the market price at closing, not the claimed $10 premium 21. No independent appraisal, certificate of analysis, storage location, or related-party determination was disclosed in the 6-K filing or F-3 prospectus 222324. Malcolm Scott Macintyre, Managing Director of Capella Capital in Sydney, received 200,000 of the 2 million shares under the same agreement as a co-seller 2526. All 2 million shares were registered for immediate resale via F-3 registration (filed February 23, 2026, effective March 4, 2026) with no lock-up period 9.
Registration Statements and Share Dilution
CRML has filed at least 5 registration statements and 23 424B3 prospectuses since December 2023, creating infrastructure for serial share resales 27. One registration covered 100,312,567 shares, representing 56.9% of shares outstanding, including all SPAC-era insiders and Cantor Fitzgerald's underwriting allocation 2827. Four F-3 shelf registrations were filed in April 2025, October 2025, February 2026, and March 2026 27. Between the copper powder F-3 becoming effective on March 4, 2026, and March 23, 2026, CRML stock declined 18% from $10.02 to $8.26 while multiple registration statements enabled share sales 29.
As a BVI-incorporated foreign private issuer, CRML is exempt from Section 16 of the Exchange Act, meaning insider sales are not reported on Form 4 and officers and directors are not subject to short-swing profit recovery provisions 30. This exemption creates a reporting gap: when the 424B3 prospectus notes that directors or officers sold shares under Rule 144, the timing and volume of those sales are not disclosed in real time 3031. Director Mykhailo Zhernov sold 500,000 shares on October 31, 2025, for approximately $628,270, and at least three additional unnamed officers sold CRML shares under Rule 144 in October 2025 31. European Lithium sold 5 million shares in January 2026 for approximately $85.5 million in gross proceeds 31.
Tony Sage Disclosure History
Tony Sage's CRML SEC filings contain no disclosure of the Australian Federal Police Operation Lemans foreign bribery investigation, the $9.36 million confiscation order granted by the Supreme Court of Victoria in May 2023, or the $96 million ATO assessment against Cape Lambert Resources 10. A comprehensive review of all CRML filings -- 20-F annual reports, F-4/A registration statement, F-1/A registration statement, and SEC correspondence -- found zero mentions of Cape Lambert, Operation Lemans, AFP, confiscation, foreign bribery, Perth Glory, or the ATO enforcement action 10.
Sage's biography in all filings describes him identically as having "35 years experience in corporate advisory services, funds management and capital raising" and lists only current ASX roles (CuFe Ltd, Cyclone Metals), omitting Cape Lambert Resources despite it being his most prominent prior company 10. Analysis of SEC Regulation S-K Item 401(f), which applies to foreign private issuers via Form 20-F Item 6.A, identifies several categories of required disclosure: judicial orders, criminal proceedings, securities law violations, and self-regulatory organization sanctions 11. The AFP confiscation order (May 2023) is a judicial order within the past 10 years, and the ASX's blocking of two Sage companies from listing constitutes a self-regulatory organization action 11.
The copper powder transaction follows a structural pattern identified in Sage's prior corporate conduct: the Cape Lambert-Fe Limited Kasombo Copper-Cobalt Project was similarly vended via share-for-asset swap, with 25 million shares plus 10 million facilitator shares plus A$125,000 cash 32. Analysis of Sage's 20-year corporate record identifies a recurring pattern of share-for-asset swaps between controlled entities, regulatory arbitrage when exchanges block deals, payments through obscured channels, offshore entity structures, and simultaneous control of multiple listed vehicles 33.
Tanbreez Rare Earth Acquisition
The Tanbreez rare earth deposit in southern Greenland is CRML's primary asset, holding a 30-year exploitation license valid to 2050 on a 4.7 billion tonne mineralized kakortokite unit containing tantalum, niobium, rare earths, and zirconium, with 28.2 million metric tons of resource and 27% heavy rare earths 34. CRML acquired its interest through a multi-stage transaction with Rimbal Pty Ltd, an Australian company controlled by geologist Gregory Barnes 35. Stage 1 (completed July 2024) secured 42% ownership for $5 million in cash and approximately 8.4 million CRML shares valued at roughly $90 million 36. A make-whole provision triggered in April 2025 awarded Rimbal an additional 5 million shares due to share price decline 36.
On September 29, 2025, the agreement was amended to replace the original $10 million exploration spending requirement with an obligation for CRML to issue 14.5 million shares to Rimbal for Stage 2, which would bring total ownership to 92.5% pending Greenland government approval 36. The exploitation license (MIN 2020-54) requires government approval for ownership changes 37. Tanbreez ownership is fully accounted for: CRML holds 92.5% and European Lithium holds 7.5%, with no room for undisclosed equity held by GreenMet or other intermediaries 38.
On March 23, 2026, CRML announced the acquisition of a majority shareholding in 60 North Greenland ApS (CVR 12716710), a Greenland logistics, drilling support, and field operations company based in Qaqortoq, near the Tanbreez deposit 14. The company, also known as Arctic Export Greenland ApS and established in 2008, will enter a collaboration agreement with Tanbreez to support infrastructure and local operational capacity 14.
Key Relationships and Network
Howard Lutnick, who became US Commerce Secretary in February 2025, held an indirect interest in CRML through Cantor Fitzgerald's 1,247,250 SPAC underwriting shares 12. Cantor received these shares as a deferred underwriting fee and private placement from the November 2021 IPO and subsequently reduced its holdings 12. Lutnick divested his Cantor stake via trust to his children, including Brandon Lutnick, in May 2025 39.
GreenMet, whose shareholders include former Trump Organization executive George Sorial, brokered CRML's partnership with Tanbreez and facilitated the EXIM Bank LOI process 13. GreenMet is absent from all 167 CRML SEC filings -- searching for "GreenMet," "Sorial," and "Schiller" across the full EDGAR record returns zero results 13. Analysis of CRML's four F-3 registration statements and three Schedule 13D/G filings found no vector through which GreenMet compensation is disclosed 4041.
Cornerstone Government Affairs registered as CRML's lobbyist in February 2025, deploying five lobbyists across defense, trade, manufacturing, and foreign relations issue areas for $210,000 over three quarters 42. The firm's stated objective was "advocacy for policy and funding support for U.S government partnerships to secure and process critical minerals, including rare earths, domestically" 43. The engagement terminated in October 2025, approximately four months after the EXIM LOI was issued 44. Michael Ryan, a former Deputy Assistant Secretary of Defense for European and NATO Policy (October 2019 to October 2020), 25-year USAF veteran, and graduate of the French War College and National Intelligence University, serves on the CRML board and was listed as the government point of contact on the SAM.gov registration 4546.
Government Financing and Federal Engagement
On June 16, 2025, the US Export-Import Bank issued a Letter of Interest to CRML for up to $120 million in financing for the Tanbreez project under a 15-year term through the Supply Chain Resiliency Initiative within the China and Transformational Exports Program 3. The LOI is not a formal loan commitment 3. Total project capital expenditure is estimated at approximately $290 million 34.
Per SME Mining Engineering, sourcing Reuters and Financial Times reporting, Trump administration officials have discussed taking a direct equity stake in Critical Metals Corp, separate from the EXIM financing 4. No prior instance of a US government direct equity investment in a BVI-incorporated mining company operating in a Danish autonomous territory has been identified 4.
CRML registered on SAM.gov on October 13, 2025, with a registration purpose of Z2 (federal contracts and grants), listing UEI XW4PVY32Q7K1, CAGE code KD8P2, and primary NAICS 212290 (Other Metal Ore Mining) 46. The registration lists a country of incorporation of the British Virgin Islands and a physical address in Winchester, United Kingdom 46. The SAM registration occurred six days after the Cornerstone lobbying engagement terminated on October 7, 2025 44.
Financial Architecture and Capital Raises
CRML reported losses of $51.9 million in fiscal year 2025 and $139.4 million in fiscal year 2024, with net cash outflows from operations of $14.5 million and $7.3 million in cash on hand as of June 30, 2025 5. European Lithium Ltd, the controlling shareholder, provided capital contributions totaling $45.7 million as of the same date, with an additional $5.85 million balance owed 47. The board identified a "significant deficiency" in internal controls, stating that the company lacks controls to ensure accurate and complete accounting for related-party transactions 47.
The largest single investment came from Alyeska Master Fund LP of Chicago, which deployed approximately $85 million across two October 2025 PIPE tranches: $35 million for 5 million new shares plus warrants, and $50 million for an additional 1.47 million shares plus pre-funded warrants 48. Alyeska also purchased 3 million shares from EUR for $21 million and 2 million from Rimbal for $14 million 49. In February 2025, CRML issued 4.91 million shares and warrants for $24.55 million to 29 accredited investors 50.
EUR reduced its stake from 58.9% to 37.3% between June 2025 and February 2026, extracting at minimum $54.75 million through secondary sales to Alyeska, plus approximately $85.5 million from a January 2026 Rule 144 sale of 5 million shares 631. The board approved $26.9 million in aggregate compensation to directors and executive officers for fiscal year 2025 51. On January 21, 2025, CRML adopted a Bitcoin treasury strategy with a $500 million convertible note program, which was terminated on October 3, 2025, as a condition of the Alyeska PIPE closing 52. A $125 million GEM Global Yield draw-down facility from July 2023 led to arbitration, resolved in March 2026 with GEM receiving 4.15 million shares total 53.
Corporate Structure and Governance
Critical Metals Corp was incorporated in the British Virgin Islands in October 2022, with its registered address at Maples Corporate Services in Tortola and its business address at 32 Harrogate Street, West Leederville, Australia 1. The company originated as Sizzle Acquisition Corp, a SPAC that Cantor Fitzgerald underwrote in November 2021 2. Following the February 2024 merger with European Lithium Ltd (ASX: EUR), EUR received approximately 80% of the combined entity 2.
Tony Sage serves as CEO and Executive Chairman, controlling CRML through European Lithium, which retains investor rights to nominate four of five directors while holding more than 50% of shares 45. The board includes Mykhailo Zhernov, managing partner of Millstone & Co Investment Company in Ukraine and former founder of ALTERA FINANCE; Malcolm Day, an EUR director since July 2012 and managing director of ASX-listed Moab Minerals; Michael Hanson, a partner at Hanson Peak LLP with postings in Russia and South Africa who chairs the Audit Committee; and Michael Ryan, the former Deputy Assistant Secretary of Defense for European and NATO Policy 45. No named director or officer reported direct beneficial ownership exceeding 1%, with Sage's interest held indirectly through European Lithium 54.
All Connections
12 total
All Connections
12 totalTanbreez offtake partnership for DoD REE supply
Cantor Fitzgerald LP is owner of CRML (LittleSis). Held 1.25M shares (deferred SPAC underwriting), divested to 190K by Q3 2025.
Alyeska Master Fund LP deployed ~$85M in two PIPE tranches in October 2025 to acquire 9.9% of CRML. Also bought ~5M secondary shares from European Lithium and Rimbal.
Schnappauf registered as Cornerstone lobbyist for CRML Q1-Q3 2025, K/quarter. Lobbied DOD, State, EXIM, EOP for critical minerals policy.
Cantor was sole book-running manager for Sizzle SPAC IPO ($155M), converted $5.7M deferred underwriting fee to 1,247,250 CRML shares, sold 87% within months of lock-up expiry
Lutnick led Cantor Fitzgerald which held 1.247M CRML shares; now Commerce Secretary influencing trade/tariff policy affecting CRML's Greenland rare earth operations. Sons Brandon and Kyle now run Cantor.
Holds 30-year exploitation license for Tanbreez deposit (potentially world's largest REE deposit, 28.2M metric tons). $120M EXIM Bank LOI.
Howard Lutnick (US Commerce Secretary) listed as indirect owner of CRML via Cantor Fitzgerald (LittleSis). Divested in May 2025 via trust to children.
JPMorgan 10B national security investment pledge + Goldman Sachs MP Materials deal creates financial ecosystem that benefits Greenland rare earth projects like CRML Tanbreez
All Findings
84 total
All Findings
84 totalfinancial (38)
Mykhailo Zhernov (CRML Director) sold 500,000 shares under Rule 144 via Oppenheimer & Co on Oct 31 2025 (approx market value $628,270). Shares acquired via issuer compensation July 1 2024 (500,000 shares). At least 3 additional unnamed officers sold CRML shares under Rule 144 in October 2025. European Lithium sold 5,000,000 shares under Rule 144 in January 2026 (gross proceeds ~$85.5M, per 6A/A Amend 6).
EXIM Bank issued Letter of Interest (LOI) to Critical Metals Corp on June 16, 2025, for up to $120 million in financing for the Tanbreez Rare Earth Project in Greenland. Loan term: 15 years. Program: Supply Chain Resiliency Initiative (SCRI) under The China and Transformational Exports Program (CTEP). Status as of announcement: LOI only -- "EXIM will consider financing" -- not a formal loan commitment. CRML expects to invest $10M in 2025 to acquire additional 50.5% of Tanbreez, bringing total ownership to 92.5%. Feasibility study expected by end of 2025. No government officials named in press release.
Going concern: CRML has substantial doubt about ability to continue as going concern. Losses of $51.9M (FY2025) and $139.4M (FY2024). Net cash outflows from operations $14.5M in FY2025. Working capital deficit (ex-share-settled liabilities) of $15.6M. Cash on hand only $7.3M as of June 30 2025. Company is pre-revenue mining exploration stage.
Beneficial ownership as of June 30 2025 (106.9M shares): European Lithium Ltd (EUR) owns 62,916,641 shares (58.9%). Rimbal Pty Ltd (Greg Barnes) owns 11,728,174 shares (11%). All named directors and officers reported ZERO beneficial ownership. As of Feb 2026: EUR reduced stake to 37.3% (45,536,338 shares) via multiple secondary sales to Alyeska.
Rimbal Pty Ltd (Australian company, controlled by geologist Gregory Barnes, 47 Labouchere Road, South Perth 6151 WA) is the second-largest shareholder at 11.0% (11,728,174 shares) as of June 30 2025 per 20-F. Shares acquired as payment for Tanbreez Stage 1 acquisition (July 23 2024: ~8.4M shares issued). Rimbal also participated as a selling shareholder in the October 2025 PIPE (sold 2M shares at $7/share = $14M). Rimbal is the entity holding Tanbreez Mining Greenland A/S and sold it to CRML.
EUR (Tony Sage's Australian mining company) has systematically reduced its CRML stake through secondary sales to Alyeska: (1) Oct 5 2025: EUR sold 3M shares to Alyeska at $7/share = $21M; (2) Oct 14-21 2025: Additional EUR reductions (Schedule 13D/A amendments 3-5 shows stake declining from ~65M to 53M shares); (3) Feb 3 2026: EUR sold 2.5M shares to Alyeska at $13.50/share = $33.75M. EUR stake went from 58.9% (June 30 2025) to 37.3% (Feb 4 2026). EUR has extracted at minimum $54.75M+ in secondary sales.
CRML executive compensation: Board approved $26,922,412 in aggregate compensation (cash + share-based) to directors and executive officers for FY2025 (year ended June 30 2025). In July 2025, 2,110,000 ordinary shares issued as equity awards valued at ~$6.9M. In April 2025, ~1.8M RSUs granted to directors vesting 1 year from grant. All compensation reported in aggregate; no individual disclosure required as foreign private issuer.
US government considering direct equity stake in CRML, separate from USD 120M EXIM loan — unprecedented state investment in Greenland mining
Per SME Mining Engineering (sourced from Reuters/FT reporting): Trump administration officials have discussed taking a direct equity stake in Critical Metals Corp, which would give Washington a direct interest in the largest rare earths project in Greenland. This equity stake would be SEPARATE from the USD 120M EXIM Bank LOI already issued. If executed, this would represent an unprecedented US government direct investment in a BVI-incorporated mining company operating in a Danish autonomous territory. This further elevates the political significance of the CRML-Tanbreez deal and the undisclosed GreenMet intermediary role.
Critical Metals Corp (CRML) holds Tanbreez rare earth deposit in Greenland — received $120M EXIM Bank LOI. Tanbreez has 30-year exploitation license valid to 2050, 28.2M metric tons, 27% heavy rare earths.
Critical Metals Corp (NASDAQ: CRML, NY-based) acquired Tanbreez deposit, potentially world largest rare earth deposit. Received $120M EXIM Bank LOI (June 2025) under Supply Chain Resiliency Initiative for 15-year term loan. Also secured $50M PIPE from unnamed institutional investor. Total project capex ~$290M. Tanbreez contains tantalum, niobium, rare earths, and zirconium on a 4.7B tonne mineralized kakortokite unit. 30-year exploitation license valid to 2050. DFS expected end 2025. This is the actual Greenland rare earth play — NOT KoBold/Disko-Nuussuaq. Separately, CSIS analysis notes Greenland ranks 8th globally for rare earth reserves at 1.5M tons. The EXIM loan represents US government financial commitment to Greenland mineral extraction.
European Lithium Limited (Australia, ASX-listed) is the controlling shareholder of CRML, having received 67,788,383 shares (83.8%) at the Feb 27 2024 merger close. As of Feb 4 2026, EL holds 45,536,338 shares = 37.3% after 7 separate sell-down transactions totaling ~22M shares. CEO Tony Sage signs all filings. Counsel: White & Case LLP (Jason Rocha), Houston TX.
IDENTIFIED: The unnamed $50M PIPE investor is Alyeska Master Fund LP (Alyeska Investment Group, Chicago IL). Two PIPE tranches: (1) Oct 5-6 2025: $35M for 5,000,000 new shares + warrant for 10,000,000 shares at $7/share expiring Oct 2031; also bought 3M shares from European Lithium ($21M) and 2M shares from Rimbal ($14M) — total ~$70M deployed. (2) Oct 15-16 2025: $50M for 1,470,000 new shares + pre-funded warrant for 1,560,303 shares. Combined Alyeska holds 9.9% (11,652,735 shares) as of Dec 31 2025 per SCHEDULE 13G.
The unnamed $50M PIPE investor from Oct 2025 is Alyeska Master Fund, L.P. (Chicago). On Oct 5 2025, Alyeska paid: (1) $35M to CRML for 5M new shares + warrant for 10M shares at $7; (2) $21M to EUR for 3M shares at $7; (3) $14M to Rimbal for 2M shares at $7. Total $70M. Brokers: Jett Capital Advisors LLC and Cohen & Company Capital Markets (J.V.B. Financial Group). CRML-issued shares comprise the company's direct PIPE.
Empery Asset Management LP (Delaware, 1 Rockefeller Plaza Suite 1205 NY) held 9.23% (7,038,345 shares + 1.4M warrant-backed shares) as of Sept 30 2024. Managing members: Ryan M. Lane and Martin D. Hoe. Position declined through 2025: 8.97% (Dec 2024), 5.15% (Mar 2025), 1.97% (Jun 2025). Empery was an early post-SPAC institutional investor now largely exited.
Feb 2025 PIPE ($24.55M): On Feb 6-7 2025, CRML issued 4,910,000 shares and 4,910,000 warrants (at $7, expiring Feb 7 2029) for $5/unit = $24.55M gross to 29 accredited investors. Sales commission: $1.473M cash plus equivalent warrants ($2.946M total). Brokers: Jett Capital Advisors LLC (712 Fifth Ave, NY), J.V.B. Financial Group LLC (3 Columbus Circle, NY), EAS Advisors LLC/Odeon Capital Group LLC (750 Lexington Ave, NY). PIPE investors are identified as 'three funds affiliated with each other' (per subscription agreement language - likely Empery Funds based on context). Same Empery Funds held prior Sizzle PIPE warrants.
CRML management table (from 20-F Jun 30 2025): Tony Sage = CEO/Executive Chairman (zero reported shares, beneficial through European Lithium); Sergey Savchenko, John Thomas, Thomas McNamara, George Karageorge, Dietrich Wanke, Michael Ryan, Malcolm Day, Michael Hanson, Mykhailo Zhernov = all listed as directors/officers, all showing 0.0% direct beneficial ownership except Zhernov (who sold shares on Form 144). No director or officer directly reported >1% beneficial ownership of CRML. EDGAR confirms insiderTransactionForIssuerExists = 0.
CRML had a Bitcoin treasury strategy adopted Jan 21 2025: $500M convertible note program ($100M initial tranche), notes convertible at $6/share with 14.28M warrants at $7/share, secured by Bitcoin escrow. Lead investor unnamed. This BTC Agreement was terminated Oct 3 2025 as a condition of the Alyeska PIPE closing. Company never executed the BTC strategy.
Technology Metals PLC (TM1) received 1,371,742 CRML shares from European Lithium in Nov 2024 in exchange for 100% of LRH Resources Ltd (which holds the Leinster Lithium project in Ireland). TM1 entered lock-up agreement with CRML preventing transfer until Feb 28 2025. This is an additional minor shareholder from a corporate transaction.
CRML stock declined 18pct from 10.02 to 8.26 during March 4-23 2026 while multiple registration statements enabled share sales
Since the Swiss Commodity Re F-3 became effective March 4, 2026 (333-293656, registering 2,777,600 shares), CRML stock fell from 10.02 (Mar 4) to 8.26 (Mar 23), an 18pct decline. During this period: (1) A SECOND F-3 was filed March 18 (333-294406) registering 2,744,062 shares for GEM Global Yield LLC SCS; (2) Director Zhernov filed Form 144 to sell 50,000 shares via Oppenheimer on March 23; (3) 9 new Form 3 (initial ownership) filings appeared March 18 for officers and directors. The March 10 volume spike (13.85M shares vs 4-8M average) with a significant price gap-up from 8.94 to 10.09 may reflect momentum trading rather than block selling. The steady decline from 10.02 to 8.26 over the period is consistent with gradual selling pressure but could also reflect broader market conditions. Key observation: CRML is a foreign private issuer exempt from Section 16 reporting, meaning insider sales need not be reported on Form 4.
CRML is a foreign private issuer exempt from Section 16 - insider sales not reported on Form 4
Critical Metals Corp is incorporated in the British Virgin Islands and qualifies as a foreign private issuer under the Exchange Act. Per the 424B3 prospectus: 'our officers, directors and principal shareholders will be exempt from the reporting and short-swing profit recovery provisions under Section 16 of the Exchange Act.' This means: (1) Officers/directors are NOT required to file Form 4 when buying or selling CRML shares; (2) The only insider reporting mechanism is the initial Form 3 filings; (3) Form 144 is only required for sales of restricted/control securities under Rule 144, NOT for sales of shares registered under an effective F-3; (4) Swiss Commodity Re (1.5pct holder, not an affiliate) has NO reporting obligation when selling registered shares. The practical implication is that sales by Swiss Commodity Re, Macintyre, or any non-affiliate selling securityholder through the registered prospectus are essentially invisible to SEC public filings until the next periodic report.
Oppenheimer is the broker for CRML insider sales - confirmed via Form 144 filings by Director Zhernov
Both Form 144 filings by Director Zhernov Mykhailo (Oct 31, 2025 and Mar 23, 2026) identify Oppenheimer and Co Inc as the broker. The Jan 14, 2026 Form 144 by European Lithium Ltd (10pct holder) used BMO Capital Markets Corp. The prospectus Plan of Distribution allows selling securityholders to use any of: ordinary brokerage transactions, block trades, broker-dealer as principal, exchange distribution, private transactions, short sales, etc. No specific broker is named for Swiss Commodity Re or Macintyre in the prospectus.
Show 18 more financial findings
CRML has filed at least 5 registration statements enabling massive share resales - pattern of serial dilution
Per the 424B3 prospectus risk factors section, CRML has filed multiple registration statements for share resales: (1) F-1 subsequently amended to F-3 (April 23, 2025) - registered 100,312,567 shares (56.9pct of outstanding); (2) Registration statements filed April 2025 and October 2025; (3) F-3 Reg 333-293656 (effective March 4, 2026) - 2,777,600 shares (Swiss Commodity Re/Macintyre/placement agents); (4) F-3 Reg 333-294406 (filed March 18, 2026) - 2,744,062 shares (GEM Global Yield). Additionally, European Lithium (10pct holder) filed Form 144 to sell 5M shares on Jan 14, 2026. The aggregate registered share overhang relative to daily volume creates significant potential dilution. With 122M shares outstanding and tens of millions registered for resale, selling securityholders have ample registered inventory to sell without any filing requirements.
CBIZ CPAs replaced Marcum LLP as auditor; 7 material weaknesses found; internal controls 'not effective'; copper booked in unaudited financials
CBIZ CPAs P.C. served as auditor for FY2025 (year ended June 30, 2025), replacing Marcum LLP who audited FY2024 and FY2023. Audit fees: CBIZ ,009 (FY2025); Marcum ,960+,760 (FY2024). Management and CBIZ identified SEVEN material weaknesses, internal controls deemed 'not effective': (1) insufficient personnel for segregation of duties, (2) related-party transaction controls: 'lacks controls needed to assure accounting for related party transactions is accurate and complete,' (3) accounts payable/accrued expenses accuracy, (4) income tax provision review, (5) complex financial instruments accounting, (6) cybersecurity program inadequacy, (7) financial statement review completeness. Going-concern qualification: 'Substantial doubt exists about ability to continue as a going concern.' The copper powder (.8M) was booked in the Dec 31, 2025 half-year financials which are UNAUDITED. First audit exposure will be FY2026 20-F (expected Oct 2026). Audit committee has only 2 members (Malcolm Day and Michael Hanson).
Copper valued at .8M (not announced M) using fair value of shares issued; no independent appraisal; no fair value hierarchy disclosed
The Nov 21, 2025 press release announced the copper deal at $10/share ($20M for 2M shares). The Dec 31, 2025 half-year equity statement records: 'Issue of shares – Acquisition of copper: 2,000 shares, $15,798,000 premium, Total $15,800,000.' This implies shares valued at ~$7.90/share (CRML market close Dec 16, 2025), not the announced $10. The $4.2M gap was never disclosed or explained. The half-year 6-K states inventory policy: 'Inventories are valued at the lower of cost and net realisable value.' The 'cost' was determined solely by the market value of shares issued — no independent assessment of whether the copper is actually worth $15.8M. No fair value measurement hierarchy (Level 1/2/3) disclosed. No independent appraisal. No observable market inputs cited. The press release $10/share claim was contradicted by the Nov 20 close of $7.23 (only 24% premium, not 40% as claimed). The stock FELL on announcement day: Nov 21 close was $7.13, down 11.4%.
Consultant fees exploded 40x in 2 years (K→.3M), promotion/IR 18x (K→.2M); no consultants named; pre-revenue company
CRML spending growth from 20-F and 6-K filings: Consultant/professional services: FY2023 $311K → FY2024 $1.384M → FY2025 $12.338M (+792% YoY, 40x in 2 years). Promotion/IR/PR: FY2023 $64K → FY2024 $191K → FY2025 $1.192M (+523% YoY, 18x in 2 years). Share-based payments: FY2023 $0 → FY2024 $608K → FY2025 $30.567M (+4,926%). Director fees: FY2023 $0 → FY2024 $137K → FY2025 $1.391M. H1 FY2026 (Dec 2025): consultants $4.49M (+362% vs H1 FY2025 $972K), promotion $1.18M (+547% vs $183K). 20-F attributes consultant increase only to 'engagement of consultants in relationship with the business combination transaction.' No individual consultants named. Combined non-operating expenses consumed ~$53M in H1 FY2026 alone. Cash outflows from operations: H1 FY2025 $2.6M → H1 FY2026 $19.2M (+638%). Company has zero revenue.
50% share dilution in 18 months (81M→125M+ shares); 120M+ shares registered for resale exceeding total outstanding; serial F-3 pattern
CRML shares outstanding: June 30, 2024: 80,994,098 → June 30, 2025: 104,790,304 → Dec 31, 2025: 121,342,258 → post-GEM Mar 2026: ~125.5M. This is 50%+ dilution in 18 months. Significant non-cash issuances: Tanbreez/Rimbal 13.4M shares ($96.85M), copper/Swiss Commodity Re 2M shares ($15.8M), RSU vesting 4.6M shares, GEM settlement 4.15M shares (2.74M for NO consideration), suppliers ~1.05M shares. CRML has filed 5+ registration statements and 23+ prospectuses since 2023. Total shares registered for resale across all F-3s exceeds 120M — more than total shares outstanding. Pattern: private issuance at favorable terms → immediate F-3 registration → no lock-up → rapid resale. Counterparties rotate: EUR/Cantor (SPAC), Alyeska (PIPE), Swiss Commodity Re (copper swap), GEM (dispute settlement). Company receives no cash from resale registrations.
Auditor context: CBIZ acquired Marcum Nov 2024; Marcum dismissed July 2025; Marcum fined $13M for systemic failures; clean opinions became 7 material weaknesses under CBIZ
Marcum LLP audited CRML FY2023-FY2024, giving clean opinions (no material weaknesses). CBIZ Inc acquired Marcum's attest business Nov 1, 2024 ($2.3B). CRML dismissed Marcum July 7, 2025 (6-K filed July 10, accession 0001213900-25-062809). No disagreements or reportable events stated. But: (1) Marcum fined $13M (SEC $10M + PCAOB $3M) June 2023 for systemic quality failures — tripled clients, 600+ SPACs, 'churning out audits at unsustainable pace.' Violations in 25-50% of audits. (2) CBIZ then found 7 material weaknesses for FY2025, controls 'not effective' — either rapid deterioration or Marcum deficiency. (3) CBIZ doesn't specialize in mining. (4) The copper powder ($15.8M, booked in unaudited H1 FY2026 financials) won't face CBIZ audit until FY2026 20-F (expected Oct 2026).
CRML half-year financial statements (Dec 31 2025, filed Mar 13 2026) show copper inventory booked at $15,800,000 as non-current asset. Valuation method: 2,000,000 shares at $7.90 per share (fair value of shares at acquisition date). No independent third-party valuation disclosed. No custody location, storage, assay certificate, or insurance mentioned in Note 6 or anywhere in the financials.
Swiss Commodity Re Limited does NOT appear in CRML's Related Party Transactions note (Note 10) in the Dec 31 2025 half-year financial statements, despite the ASA being a $15.8M transaction. The entire related party section covers only European Lithium Ltd.
No SEC comment letters (UPLOAD or CORRESP) filed by SEC staff against CRML after Dec 1 2025 copper deal. Most recent CORRESP was April 10 2025 (F-3 acceleration request). No SEC staff challenge to the F-3 or copper valuation detected through EDGAR submissions as of March 23 2026.
CRML press release (Nov 21 2025, Exhibit 99.1 to 6-K) makes fabricated valuation claims: describes copper as selling 'between US$1,500 to US$2,500 per gram' (which would value 40kg at $60M-$100M). The claim is false - ultra-high purity copper powder trades at roughly $20-400/kg commercially. Press release also describes Swiss Commodity Re as 'a long-only multi-generational European based single family office' despite the entity being incorporated 22 days prior in HK.
CRML balance sheet as of Dec 31 2025: Copper inventory classified as NON-CURRENT asset ($15,800,000). This accounting classification itself is an admission that the company does not expect to sell or consume the copper within 12 months. This contradicts the press release portrayal of copper as an active commercial inventory for immediate monetization.
The Nov 21 2025 press release stated 2M shares at $10/share = $20M. The actual share price at acquisition close (Dec 16 2025) resulted in a booking of $15.8M (2M shares at $7.90/share). The F-3 also describes '1,800,000 ASA shares' to Swiss Commodity Re and '200,000 ASA shares' to Macintyre - consistent with 2M total but split differently than initially reported. The $20M valuation from the announcement was inflated versus the $15.8M actually booked.
European Lithium Ltd (ASX: EUR), a 10% CRML shareholder, filed Form 144 on January 14, 2026 to sell 5,000,000 CRML ordinary shares via BMO Capital Markets Corp (aggregate market value .8M). Tony Sage is Executive Chairman of European Lithium. This represents a major insider sell-down occurring shortly after the F-3 became effective. Swiss Commodity Re's 2M shares registered via F-3 (effective March 4, 2026) — no Form 144 filed by SCR as of March 24, 2026. Macintyre 200K shares: no Form 144 filed.
CRML stock declined from approximately USD 9.40 on March 4, 2026 (F-3 effectiveness date) to USD 7.68 on March 23, 2026 — an 18.3% decline in 19 days during the resale window. Feb 20, 2026 close was USD 9.06. CRML stock up 158% YTD in 2026 prior to F-3 effectiveness. The F-3 covers 2,777,600 shares total (2M ASA + 777,600 placement agent warrants). Separately, European Lithium (39.5% shareholder, controlled by Tony Sage) sold 5,000,000 shares on January 14, 2026 via BMO Capital Markets for approximately USD 73.8M total.
VALUATION CONTRADICTION: Press release (Nov 21, 2025) states '2,000,000 shares at $10/share = $20M.' 6-K form (Nov 25, 2025) states '2,000,000 shares... valued by the Company and the Seller at $20,000,000.' Financial statements (Dec 31, 2025) book at $15,800,000 — being '2,000,000 shares at $7.90/share, being the fair value of the shares as at the date of acquisition.' The $4.2M difference is the gap between (a) CRML's stock price on November 21 ($10) when deal was announced, and (b) CRML's stock price on December 16 ($7.90) when it actually closed. This means CRML announced a $20M deal but was only able to deliver $15.8M in stock value — a 21% shortfall. No 8-K or 6-K was filed to disclose the revised valuation. The equity statement shows this as 'Issue of shares – Acquisition of copper: 2,000 [shares] $15,798,000 [premium].' The ASA agreement itself has not been filed as an SEC exhibit.
H1 FY2026 net loss: $120.4M (up 536% from $18.9M). Dominant drivers: (1) warrant fair value loss -$80.1M, (2) share-based comp -$18.7M, (3) finance costs -$14.7M, (4) listing cost settlement -$9.5M. Net cash used in operations: -$19.2M. Basic loss per share -$1.07 vs -$0.21.
Note 20 post-period events (after Dec 31, 2025): (1) Jan 21, 2026 — 210,000 shares to advisory board for ~$3.2M. (2) Feb 2, 2026 — 400,000 shares to 'suppliers' in settlement of services to 'one of the Company advisors in connection with the marketing and investor relations agreement' for ~$5.0M. Combined ~$8.2M in share-based payments to undisclosed advisors within 5 weeks of period end.
CRML accounting policy for copper: 'Inventories are valued at the lower of cost and net realisable value.' The NRV is explicitly named as a KEY ESTIMATE requiring management judgement. Non-current inventory classification used: 'not expected to be consumed or processed within the next 12 months.' The company acknowledges it cannot sell the copper within one year — meaning no near-term NRV test via actual transaction price is imminent.
relationship (4)
CRML Q1 2025 lobbying report (filed 2025-04-21, income $70,000): issue areas shifted to include Trade (TRD), Manufacturing (MAN), and Budget/Appropriations (BUD) in addition to Defense and Foreign Relations. Description: "Advocacy for policy and funding support for U.S government partnerships to secure and process critical minerals, including rare earths, domestically." This lobbying language encompasses both domestic sourcing and Greenland/allied nation sourcing.
Cornerstone Government Affairs filed Q3 2025 Termination report for Critical Metals Corp on October 7, 2025 (income: $70,000). The lobbying engagement ran Feb-Sep 2025 and terminated approximately 4 months after the EXIM LOI was issued (June 16, 2025). The termination may reflect that the key government relationship goal (EXIM LOI) was achieved. CRML registered on SAM.gov on October 13, 2025 -- just 6 days after lobbying terminated -- suggesting preparation for potential direct federal procurement.
Cornerstone Government Affairs, Inc. (800 Maine Ave SW, Washington DC 20024) registered as lobbying firm for Critical Metals Corp on Feb 10, 2025. Filed 4 LDA filings: Registration Q1 2025, Q1 Report ($70K income), Q2 Report ($70K income), Q3 Termination ($70K income). Total lobbying income: $210,000 across Feb-Sep 2025 engagement. Issue areas: DEF, ENG, FOR, SCI, COM (Q1), then TRD, DEF, MAN, COM, FOR, BUD (Q2-Q3). Lobbyists: Matt Schnappauf, Adam Yezerski, Sarah Venuto, Anthony Lazarski, Joseph Barton.
Critical Metals Corp has the highest betweenness centrality (0.3119) in the entire network, bridging Greenland resources, JPMorgan finance, and defense procurement
Structural observation: Critical Metals Corp tops the betweenness ranking despite having only degree 18 (rank 6). This means it sits on more shortest paths between other nodes than any entity including Elon Musk. It connects the Greenland resource extraction cluster (Tanbreez, GreenMet, Ucore), financial institutions (JPMorgan Chase, Cantor Fitzgerald, Alyeska), government financing (EXIM), and lobbying (Cornerstone Government Affairs). The entity is a literal bridge between the Greenland development story and the financial/political apparatus. 35 findings documented but concentrated in a single thread.
legal (2)
CRML supplemental risk factors (Exhibit 99.3, filed Mar 13 2026) disclose a MATERIAL WEAKNESS specifically identified as: 'the Company identified a material weakness related to valuation and accounting for copper powder acquired in the period, in addition to material weaknesses previously identified, which remained not remediated as of December 31, 2025.' This is the company's own admission that the copper valuation is internally problematic.
Exhibit 99.3 to 6-K filed Mar 13 2026: Full material weakness disclosure reads: 'For the half year period ended December 31, 2025, the Company identified a material weakness related to valuation and accounting for copper powder acquired in the period, in addition to material weaknesses previously identified, which remained not remediated as of December 31, 2025.' Context: this disclosure appears in a supplemental risk factor update, NOT in the financial statements themselves. The half-year financial statements (Exhibit 99.2) are explicitly marked UNAUDITED. CBIZ CPAs P.C. (auditor) did not issue a review report for the half-year period — the financials are management-prepared without any auditor review attestation.
intelligence (18)
March 18, 2026: Nine CRML insiders filed Form 3 (initial ownership) — Sage Antony William Paul (Tony Sage), Zhernov Mykhailo, Day Malcolm Raymond, Savchenko Sergey (CFO), Hanson Michael J., McNamara Thomas M., Thomas John Harper, Ryan Michael C., Wanke Dietrich. This confirms the full CRML board/management composition as of that date. No Form 4 (actual insider sales) has been filed by any of these persons as of March 24, 2026.
CourtListener party API returned 403 Forbidden (no access). CourtListener full-text search 'Critical Metals Corp' returned 20 generic metals company hits — none matching CRML. 'Tanbreez' search returned 0 results. No federal litigation found for Critical Metals Corp or Tanbreez. Absence notable: NYSE-American listed company with Greenland strategic asset has zero US federal court presence.
OpenSanctions: Zero hits for Critical Metals Corp, Tanbreez, Rimbal Pty Ltd, Gregory Barnes, Tony Sage. Howard Lutnick appears as PEP (Politically Exposed Person) only — role.pep from Wikidata, no sanctions. No debarment, exclusion, or watchlist entries for any CRML-associated entity. Clean sanctions profile across all principals.
SYNTHESIS: CRML is a BVI-incorporated, pre-revenue rare earth shell with going concern doubt that has become the primary vehicle for US government-backed Greenland mineral extraction. Key network connections: (1) Cornerstone Government Affairs lobbied for BOTH CRML and Anduril — shared firm with SVDG-affiliated lobbyist Schnappauf bridging defense-tech and mining. (2) Cantor Fitzgerald owns CRML shares via Sizzle SPAC underwriting; Howard Lutnick (Commerce Sec) was indirect owner until May 2025 divestiture to sons — active Senate conflict-of-interest scrutiny. (3) Michael Ryan (former DDASD NATO/European Policy) placed on CRML board March 2025, coinciding with EXIM LOI pursuit. (4) GreenMet brokered the Tanbreez deal but is COMPLETELY ABSENT from 167 SEC filings — compensation structure deliberately kept off public record. (5) European Lithium (Tony Sage parent) selling down from 84% to 37% extracting $200M+ while CRML has $7.3M cash and $52M annual losses. (6) $50M PIPE investor is Alyeska Master Fund (Chicago, 9.9% holder, $70M+ total). (7) Swiss Commodity Re: mysterious $20M copper powder purchase — possible dilution vehicle. (8) Former Greenland Deputy Minister Schonwandt drafted mining law now consulted by Tanbreez — regulatory capture. The overall picture: a financially precarious BVI shell with Trump-network board placement, shared defense-tech lobbying infrastructure, and a deliberately opaque intermediary (GreenMet) channeling US government financing to Greenland rare earths.
SYNTHESIS (Wave 4): Two vectors deepened. (1) RTSKHILADZE-ASBESTOS: Giorgi Rtskhiladze (Mueller Report figure, Toroil/Silk Road CIS network) paid $1.2M to Javelin for EPA chrysotile lobbying Q3 2025. No FARA registration. Russian/Kazakh chrysotile producers (Uralasbest/Kostanai, 68% global output) are primary beneficiaries of ban delay. OxyChem was sole US importer from Brazil/China — Russia/Kazakhstan would be next source post-Brazil ban. FARA hypothesis structurally plausible but no direct Rtskhiladze-producer link found. Javelin's Q3 2025 client roster is a CIS geopolitical cluster: Ukraine tech (Capstone), Russian-linked asbestos (Logical Strategies), critical minerals (NioCorp). (2) I-MEI/SAGE: I-MEI Foods Taiwan cluster confirmed as tightly controlled by chairman Chih Shang Kao (also runs Golden Saddle drone factory). Chelpis Quantum has genuine NIST PQC credentials. Targeting DoD contracts under NDAA Taiwan drone provision. Tony Sage portfolio fully mapped: CRML/EUR(39.5% of CRML)/CuFe/Cape Lambert/Okewood hub. AFP Operation Lemans allegations (bribery, insider trading, offshore loans) unresolved since 2012.
CRML copper powder deal structural comparison to Sage's prior transactions: follows same share-for-asset template as Cape Lambert-FEL Kasombo deal, but with critical differences — no independent valuation, disputed commodity pricing, no established seller relationship, BVI incorporation shields from ASX-style scrutiny
COMPARATIVE ANALYSIS of CRML copper powder deal vs Sage's historical share-for-asset transactions: SIMILARITIES: (1) Asset acquired for share consideration at a premium (CRML: 40% premium; Cape Lambert-FEL: shares at VWAP); (2) Non-cash transaction avoiding cash outflow from a cash-poor entity (CRML had $7.3M cash, $52M annual losses); (3) Shares issued in private placement exempt from registration; (4) Transaction creates paper value on balance sheet without cash expenditure. CRITICAL DIFFERENCES: (1) VALUATION: Cape Lambert's mining tenement transactions had geological reports, resource estimates, and comparable transaction benchmarks. The copper powder has no disclosed independent valuation and market sources dispute the $1,500-2,500/g pricing as 2-3 orders of magnitude too high; (2) SELLER RELATIONSHIP: Prior deals (Kasombo, CopperCo, African Iron) involved identifiable mining industry counterparties. Swiss Commodity Re is a HK corporate services entity whose director Kenneth Deayton has no mining/commodities background — he's a CPA/Deloitte/HSBC veteran running corporate services; (3) REGULATORY OVERSIGHT: Cape Lambert's ASX deals were subject to ASX listing rules, continuous disclosure, and ASIC oversight. CRML is BVI-incorporated, NASDAQ-listed as a foreign private issuer — reducing regulatory scrutiny compared to ASX; (4) FACILITATOR SHARES: The Kasombo deal included 10M 'facilitator shares.' The copper powder deal includes 200K shares to Malcolm Macintyre — his role is equally opaque; (5) SCALE OF PREMIUM: A$20M for 40kg of copper powder (A$500K/kg) vs established market pricing suggests the transaction may be a mechanism to issue shares at a discount rather than a genuine commercial acquisition. STRUCTURAL HYPOTHESIS: The copper powder deal may serve a similar function to Sage's prior share-for-asset swaps — creating paper asset value while issuing shares to specific parties — but the extreme pricing anomaly and lack of independent verification distinguish it from standard mining industry practice.
SEC FILING DEFICIENCIES in copper powder transaction: The 6-K filing for the Swiss Commodity Re copper powder acquisition is remarkable for what it OMITS: (1) No independent appraisal or valuation methodology. (2) No purity specification -- the 6-K says only 'ultra-high-purity copper powder' without stating 99.96% or any numeric purity. (3) No assay report or certificate of analysis. (4) No storage/custody location. (5) No seller background or verification. (6) No related-party determination. (7) No lock-up on shares. (8) No risk factors. The press release (which is NOT an SEC filing) contains the specific purity claim and the ,500-2,500/gram pricing assertion, but the actual 6-K filing contains neither. This creates a gap: the inflated valuation claims are in marketing material, not in the regulated filing, potentially providing legal cover while still deceiving investors.
Financely Group published detailed copper powder fraud warning in September 2025, two months before CRML deal — describes identical scheme
Financely Group (financial advisory firm specializing in commodity fraud detection) published 'Why Every Ultra Fine Copper Powder and Nickel Wire Deal is a Scam' in September 2025, two months before CRML announced its copper powder acquisition (Nov 21, 2025). The article describes the CRML scheme exactly: sellers claim possession of impossibly valuable copper powder, products stored in Swiss Free-Zones with unverifiable custody, attached Safe Keeping Receipts from offshore banks, no mass balance (tonnage claims do not reconcile with packaging), photos are stock images, wrong pricing math quoting high-purity metal prices for off-spec material. Conclusion: 'This is a scam. The product is junk and the valuation is a fairy tale.' The Institut fuer Seltene Erden (Lucerne, Switzerland) separately notes significant quantities of ultrafine copper powder have 'disappeared into bank vaults worldwide' — a reference to the financial fraud usage of this product. Financely has published at least 7 analyses of this specific fraud type.
EDGAR full-text search: 'ultra-high-purity copper' appears in exactly 5 SEC filings — all CRML. Term does not exist in any other company's filings.
EDGAR EFTS full-text search confirms: (1) 'ultra-high-purity copper' returns 5 results, all CIK 0001951089 (CRML). No other public company in SEC history has used this phrase. It is not an industry-standard designation. (2) 'Swiss Commodity Re' returns 7 results, all CRML. The counterparty has zero regulatory footprint outside CRML filings. (3) 'Malcolm Scott Macintyre' returns 2 results, both CRML (F-3 and 424B3). (4) 'Hong Kong Corporate Services Group' returns 0 results outside CRML. Neither the counterparty, the product terminology, nor the co-recipient exist anywhere in the SEC filing universe outside CRML's own disclosures.
CRML proposed JV with Romanian state nuclear company Nuclearelectrica for processing facility in Feldioara, Brasov — Jan 2026
HotNews.ro reported (January 24, 2026) that Critical Metals Corp proposed a joint venture with Nuclearelectrica (Romania's state nuclear energy company) for a processing facility in Feldioara, Brasov County, Romania. The article's headline translates as 'What connects Feldioara to Greenland: The question marks of the economic deal proposed to the Romanian state.' Journalist Claudia Parvoiu raises skepticism about the proposal. This adds Romania to CRML's growing list of announced partnerships/proposals (Greenland, Saudi Arabia, US EXIM Bank) that create narrative value without requiring near-term execution. A pre-revenue BVI shell with $7.3M cash and going-concern doubt proposing industrial JVs with state nuclear companies fits the pattern of ambitious announcements designed to support stock price during selling periods.
F-3 for copper shares effective in 9 days (unusually fast); promotional press release cadence intensified precisely during resale window
The F-3 registration for copper powder shares filed Feb 23, 2026 was declared effective Mar 4, 2026 — a 9-day gap, unusually fast (typical: 30-60 days). Total time from deal close (Dec 16) to freely sellable shares: 78 days. No lock-up period. Stock data around key dates: Nov 21 announcement — stock FELL (close $7.13, down 11.4%). Feb 23 F-3 filing — volume nearly doubled (11.6M shares), price $10.31. Mar 4 effective — $10.02. Mar 5-6 post-effective — immediate 12% decline to $8.80. Mar 23 current: $8.26, down 18% from effectiveness. CRML issued a barrage of press releases Jan-Mar 2026 (Saudi Arabia $1.5B term sheet, drilling results, lab acquisition, pilot plant, project management team, $30M acceleration program, 60 Degree North acquisition) precisely coinciding with the F-3 filing and effectiveness window — creating selling opportunities through elevated prices and volume. No Form 144 filings yet by Swiss Commodity Re or Macintyre as of Mar 23, 2026.
CONTRADICTION: Financial statements (Note 6, Note 12, equity statement) state '2,000,000 shares issued to the Seller' and 'Issue of shares - Acquisition of copper: 2,000,000 shares at $15.8M.' The F-3 prospectus (Feb 23, 2026, accession 0001213900-26-019356) discloses the shares were split: 1,800,000 to Swiss Commodity RE Limited and 200,000 to Malcolm Scott Macintyre separately. Note 3 of F-3: 'Consists of 1,800,000 Ordinary Shares received by the Selling Securityholder in accordance with the ASA. Kenneth Raymond Deayton may be deemed to have voting and investment control over the securities held by Swiss Commodity RE Limited. The business address for this Selling Securityholder is 6th Floor, Wyndham Place, 40-44 Wyndham Street, Central, Hong Kong.' Note 4: 'Consists of 200,000 Ordinary Shares received by the Selling Securityholder in accordance with the ASA. The business address for this Selling Securityholder is 22 Faraday Avenue, Rose Bay, New South Wales, 2029, Australia.' The financial statements' description of '2,000,000 shares to the Seller' obscures Macintyre's separate 200,000 share allocation.
CRML filed NO announcement or closing notice for the December 16, 2025 copper powder transaction close. The 6-K filed November 25, 2025 announced the deal and stated it would 'close within 10 business days.' Review of all 6-K filings between Nov 25, 2025 and Mar 13, 2026 shows: Dec 12, 2025 6-K (FPCU term sheet only); Dec 31, 2025 6-K (AGM vote results only); Jan 21, 2026 6-K (Saudi offtake MoU only). No 6-K or current report was filed to announce the closing of the $20M copper deal. The F-3 (Feb 23, 2026) first discloses 'The closing of the transactions contemplated by the ASA occurred on December 16, 2025' — the public learned of the closing only through the registration statement, not a dedicated current report. This is unusual for a material transaction.
INTERNAL CONTRADICTION in Nov 21 press release: (1) 'The Company will issue 2 million Ordinary shares at $US10 per share for 40 kilograms of the UHP 99.96% pure copper powder.' (2) The 'About Copper Powder' boilerplate section in the SAME press release states: 'Ultra High Purity (UHP) copper powder, often achieving purity levels of 99.9999% or higher, is a specialized material prized...' — describing a DIFFERENT grade of copper. 99.96% purity (4N = 99.99% is standard, so 99.96% is below even standard 4N) is not the same product as 99.9999% (6N). The press release uses inflated 6N pricing references to justify 99.96% copper. Additionally, the 6-K form body only says 'ultra-high-purity copper powder' without ANY purity figure — the 99.96% claim appears only in the press release exhibit, not in the actual SEC form, and is inconsistent with the general boilerplate used to justify the price.
SYNTHESIS: CRML copper powder physical non-existence — zero chain-of-custody evidence across all sources. No custody location, custodian, warehouse receipt, assay certificate, insurance policy, shipping record, or import/customs documentation found in: (1) any CRML SEC filing including 6-K Nov 2025, F-3 Feb 2026, 424B3 Mar 2026, half-year financials Dec 31 2025; (2) EDGAR full-text search across all CRML filings for custody/warehouse/assay/storage/insurance/shipping; (3) open web searches; (4) corporate registries; (5) trade data sources. The only location language is accounting boilerplate: 'costs incurred in bringing inventory to its present location.' A $15.8M non-current inventory asset has no physical address in any disclosure. The copper powder's physical existence cannot be verified from any public source.
SYNTHESIS: CRML copper powder — two-tier disclosure architecture provides legal cover. All promotional claims appear exclusively in the press release exhibit (Exhibit 99.1 to 6-K), not in the regulated form body: 'European based single family office,' 'G7 & EU-origin,' 'NATO supply capabilities,' 'traceable supply chain,' '$1,500-2,500/gram' price. The regulated 6-K form body states only that CRML entered an agreement to acquire copper. This bifurcation mirrors professional securities fraud methodology: make material misstatements in an exhibit-only press release to generate stock price movement while the regulated filing contains minimal verifiable claims. No SEC comment letters issued after April 2025 suggest SEC has not yet reviewed the Nov 2025 transaction.
SYNTHESIS: CRML copper powder — no auditor has ever reviewed or opined on the copper valuation. CBIZ CPAs P.C. (PCAOB #199) audited CRML through June 30, 2025 — two months before the copper deal. The half-year financials (Dec 31, 2025) containing the $15.8M copper are explicitly marked '(Unaudited)' throughout with no auditor review report. The material weakness disclosure ('valuation and accounting for copper powder') is a management disclosure in a supplemental risk factors exhibit, not an auditor-identified finding. CBIZ was ratified as FY2026 auditor on Dec 29, 2025 — after the copper accounting problem already existed. CBIZ's 2024 PCAOB inspection found a Long-Lived Asset deficiency (failure to look beyond management's own analysis) directly relevant to the copper. No auditor has issued any opinion, review conclusion, or emphasis-of-matter paragraph on the $15.8M copper inventory.
SYNTHESIS: CRML copper powder — evolved copper SKR fraud adapted for public equity markets. Financely Group documented the classic template (July 2025, 4 months pre-CRML): storage in Swiss free zone, $1,500-2,500/gram price claim, 'multi-generational European family office' seller, G7/EU-origin claim, no documentation. CRML variant innovates by replacing the defrauded lender with public shareholders: instead of soliciting private financing against phantom collateral (which requires documentation from lenders), CRML issued 2M liquid NASDAQ shares. No single party demands a warehouse receipt. The result: Swiss Commodity Re (Kenneth Deayton, HK corporate services) receives $15.8-20M equivalent in NASDAQ shares for copper of undisclosed provenance; Malcolm Macintyre receives $1.58-2M shares as apparent deal arranger; Jett Capital (Darrin Blumenthal, ABN AMRO Sydney alum) links Macintyre to CRML as financial advisor. The public market — not a lender — absorbs the phantom collateral risk.
identity (3)
Critical Metals Corp SAM.gov registration: UEI XW4PVY32Q7K1, CAGE code KD8P2. Incorporated in British Virgin Islands (country_of_incorporation: VGB). Physical address: Itchen Down House, Northington Road, Itchen Down, Winchester, SO21 1BT, UK. Entity start date: 2022-10-14. Registered in SAM: 2025-10-13, active 2025-10-15, expires 2026-10-13. Government POC: Michael Ryan (Director). Primary NAICS: 212290 (Other Metal Ore Mining). Purpose of registration: Z2 (federal contracts/grants). No exclusions.
CRML leadership and board composition (2025)
CEO/Exec Chairman: Tony Sage (since Apr 2024, Australia). CFO: Sergey Savchenko. CTO: George Karageorge. IR: Thomas McNamara. GC: John Thomas. Directors: Zhernov, Hanson (Audit), Ryan, Trabuco. CIK 0001951089 (fka Sizzle Acquisition Corp). 104.9M shares outstanding Jun 30 2025.
CRML SPAC origin: Sizzle Acquisition Corp (NASDAQ: SZZLU) raised M IPO Nov 2021 with Cantor Fitzgerald as underwriter. Merged with European Lithium Ltd (ASX: EUR) to form Critical Metals Corp, listed Feb 28, 2024. EUR received ~80% of CRML. Cantor received 1,247,250 shares total: 47,250 from IPO private placement + 1,200,000 as deferred underwriting fee (deemed issue price .79). CIK 0001951089.
document (17)
GEM Global Yield LLC SCS credit facility and dispute: July 4 2023 CRML entered $125M draw-down facility with GEM. 122,549 commitment fee shares and 1,814,797 warrants issued. GEM exercised warrant right Feb 27 2025 demanding $27.2M in shares. CRML entered arbitration with counterclaims. Also owed GEM cash payment of $3.5M (10% annual interest). Resolution: March 5 2026, GEM Agreement terminated the SPA. GEM received 1,409,624 shares (warrant exercise) + 2,744,062 shares for no consideration (settlement). CRML files registration for 2.744M resale shares.
CRML is incorporated in British Virgin Islands as holding company. CIK 0001951089. Files as foreign private issuer (20-F). Business address: 32 Harrogate Street, West Leederville, Australia (Tony Sage office). BVI registered address: Maples Corporate Services, Tortola. Incorporated 2022. Fiscal year ends June 30. 104,912,853 shares outstanding as of June 30 2025.
CRML related-party transactions (from Note 17): EUR (parent) has provided capital contributions totaling $45.7M to CRML and its subsidiaries as of June 30 2025. Additional balance owed to EUR: $5,854,852 (vs $4,268,857 at June 30 2024). EUR essentially financed CRML operations pre-PIPE. Board identified 'significant deficiency' in internal controls: 'The Company lacks the controls needed to ensure that the accounting for its related party transactions is accurate and complete' due to lack of personnel.
March 4, 2026 424B3 prospectus confirms: Swiss Commodity RE Limited held 1,800,000 shares (1.5%), Malcolm Scott Macintyre held 200,000 shares (<1%), Jett Capital Advisors Holdings LLC held 427,500 warrant shares, Cohen & Company Securities LLC held 350,100 warrant shares — all registered for resale, no lock-up, freely tradeable as of March 4
Cantor Fitzgerald's role in CRML: Cantor was the underwriter of the Sizzle Acquisition Corp (SPAC) IPO, NOT a direct CRML placement agent. At the Feb 27 2024 SPAC merger closing, Cantor received 1,247,250 CRML ordinary shares as compensation: 1,200,000 shares as the deferred underwriting fee for the Sizzle IPO, and 47,250 representative shares purchased in a private placement in connection with the Sizzle IPO. EBC (another party) received 75,600 shares. Total Cantor/EBC: 1,322,850 shares.
GreenMet (Sorial/Schiller) does NOT appear in any CRML SEC filings. Zero results searching all EDGAR filings for 'GreenMet', 'Sorial', 'Schiller' in context of CRML. Their brokerage/introduction role is not disclosed as a related-party transaction or material agreement in mandatory SEC filings. Either the GreenMet role was non-compensated (unlikely), predates SEC reporting obligation, or the relationship is disclosed only in private agreements not required to be filed.
Tanbreez acquisition structure from SEC filings: (1) Jun 5 2024: Heads of Agreement with Rimbal Pty Ltd (Gregory Barnes) to acquire interest. (2) Jun 18 2024: 5.55% interest acquired for $5M cash to Rimbal. (3) Jul 23 2024: Additional 36.45% interest (Stage 1) acquired for ~8.4M CRML shares (value ~$90M at issuance) = 42% total. EUR retains 7.5%. (4) Make-whole provision: Apr 28 2025, Rimbal received 5M additional shares at $1.37/share ($6.85M deemed value) due to share price decline. (5) Sep 29 2025: HoA Amendment removes $10M exploration requirement, instead obligates CRML to issue 14.5M shares to Rimbal for Stage 2 (92.5% total). Stage 2 still requires Greenland government approval.
Board composition (FY2025 20-F): 5 directors total. Class I: Mykhailo Zhernov (EUR director since Dec 2021; managing partner Millstone & Co Investment Company, Ukraine; former ALTERA FINANCE founder). Class II: Malcolm Day (EUR director since Jul 2012; MD of ASX:MOM Moab Minerals since 1999) and Michael Hanson (partner, Hanson Peak LLP; 30 yrs natural resources/corporate finance; postings Russia and South Africa). Class III: Tony Sage (CEO/Executive Chairman) and Michael C. Ryan (independent; former Deputy Asst Secretary of Defense for European/NATO Policy Oct 2019-Oct 2020; 25 yrs USAF, Colonel; graduate French War College; National Intelligence University). EUR controls majority board via investor rights agreement (can nominate 4 of 5 while >50% shareholder).
CRML Bitcoin treasury strategy: Jan 21 2025, CRML announced board approval of Bitcoin as primary treasury asset and entered $500M senior convertible note purchase agreement with unnamed 'lead investor'. Initial closing of $100M planned. Notes convertible at $6.00/share; warrants at $7.00. Bitcoin purchase conditions included market cap exceeding $820M. On Oct 3 2025, CRML terminated this agreement (BTC Agreement), contingent on closing of the Alyeska PIPE. BTC strategy abandoned entirely.
CRML Nov 25 2025: Entered Asset Sale Agreement with Swiss Commodity Re Limited (unknown entity). CRML purchased 40kg of ultra-high-purity copper powder from this Swiss company in exchange for 2,000,000 ordinary shares (valued by both parties at $20,000,000 = $10/share). Issuer explanation is that this gives CRML tangible commodity assets. Swiss Commodity Re Limited is unidentified - no prior appearance in CRML filings. Related party or arm's-length transaction unclear.
CRML's Nov 21 2025 ASA closed December 16 2025. The F-3 was filed Feb 23 2026 and became effective March 3-4 2026. The 424B3 (final prospectus) was filed March 4 2026 making shares immediately sellable. Timeline: incorporated Oct 30 (22 days before deal) -> deal Nov 21 -> closed Dec 16 -> F-3 filed Feb 23 -> effective Mar 4 (76 days total from close to registration). No lock-up period whatsoever.
Note 6 (Inventory) of CRML half-year financials (Dec 31 2025): Full text states 'On November 21, 2025, the Company entered into an Asset Sale Agreement (the ASA) with Swiss Commodity Re Limited (the Seller) and purchased 40kg of ultra-high-purity copper powder from Seller. Under the terms of the ASA, the transaction completed on December 16, 2025 when the Company issued the Seller a total of 2,000,000 ordinary shares.' No custody, storage, location, assay, or insurance language anywhere in the note. Cost stated as '2,000,000 shares at $7.90 per share, being the fair value of the shares as at the date of acquisition.'
CRML half-year financials accounting policy for inventory explicitly says 'Costs incurred in bringing CRML's inventory to its present location and condition are accounted for on a weighted average basis' and 'Inventory classified as non-current represent inventories not expected to be consumed or processed within the next 12 months and relate to ultra-high-grade copper powder.' The phrase 'present location' implicitly acknowledges a physical location exists but the location is never disclosed. The key estimate section references 'variables affecting costs recognised in bringing the inventory to its location and condition for sale' without naming any location.
Note 10 (Related Party Transactions) of CRML half-year financials (Dec 31 2025) contains ZERO mention of Swiss Commodity Re Limited or Malcolm Scott Macintyre. Note 10 only discloses: (1) European Lithium Ltd (EUR) working capital advance of $2,355,328; (2) Tony Sage remuneration increase to $750,000/year via Okewood Pty Ltd; (3) EUR share sales generating $124.475M. The $15.8M copper powder acquisition from a 3-week-old HK entity run by a corporate services provider is not classified as a related party transaction, despite CRML having identified 'related party transactions' as a specific pre-existing significant deficiency in internal controls.
CBIZ CPAs P.C. audit report for year ended June 30, 2025 (dated October 3, 2025, filed in 20-F Oct 6 2025): Contains (1) clean opinion — financial statements 'present fairly, in all material respects'; (2) Explanatory Paragraph for Going Concern — 'the Company has a significant working capital deficiency, has incurred significant losses and needs to raise additional funds'; (3) NO reference to copper powder (deal not yet done); (4) No mention of material weaknesses in the audit report itself — only significant deficiencies in management's assessment. The half-year financials (period Dec 31 2025) are filed with NO CBIZ review report — marked '(Unaudited)' throughout. CBIZ did not issue any review of the interim period containing the copper transaction.
The 6-K form body (regulated filing, Nov 25 2025, accession 0001213900-25-114760) states: 'the Company purchased 40kg of ultra-high-purity copper powder from Seller in exchange for a total of 2,000,000 ordinary shares... valued by the Company and the Seller at $20,000,000.' The press release (Exhibit 99.1, same accession) additionally claims: 'secured one of the largest strategic stockpiles of ultra-high-purity critical copper powder,' 'G7 & EU-origin secured stockpiles,' 'fully compliant, highly sought after, traceable supply chain,' 'long-only multi-generational European based single family office,' 'DoW and NATO supply capabilities,' 'supplies our allied militaries immediately.' NONE of these promotional claims appear in the regulated 6-K filing itself. The form body does not disclose purity percentage, location, G7/EU origin, NATO/DoW context, or any supply chain details. This creates a two-tier disclosure: inflated marketing claims in the press release vs minimal factual disclosure in the regulated form.
CRML 20-F annual report (year ended June 30, 2025, filed Oct 6 2025, accession 0001213900-25-096254) discloses six pre-existing significant deficiencies in internal controls, including specifically: 'The Company lacks the controls needed to assure that the accounting for its related party transactions is accurate and complete.' This pre-existing deficiency was known BEFORE the copper powder deal closed on Dec 16, 2025. The subsequent identification of a 'material weakness related to valuation and accounting for copper powder' suggests the copper deal exploited the exact control gap that existed. The 20-F also discloses CBIZ audit report included an Explanatory Paragraph for Going Concern (working capital deficiency, significant losses, need to raise additional funds).
negative_result (2)
Zero physical evidence for copper powder across 10 categories — no customs, storage, assay, insurance, transport, warehouse receipts, manufacturer, appraisal, inspection, or custody records
Comprehensive search across all available databases found zero physical evidence for the 40kg copper powder ($15.8M): (1) Customs/import: No records in US, AU, or HK customs databases for copper powder by CRML or Swiss Commodity Re. HS Code 7406 avg import price $10.35/kg — 40kg would declare at ~$414, not $20M. (2) Storage: No location ever disclosed in any filing. (3) Warehouse receipt/SKR: Never disclosed. (4) Assay/certificate of analysis: Never disclosed; purity claims self-contradictory (99.96% AND 99.9999% in same press release). (5) Insurance: No cargo or storage insurance disclosed for a $15.8M asset. (6) Independent appraisal: Never obtained. (7) Manufacturer: No supply chain documented; no connection to any known UHP copper manufacturer. (8) Physical inspection: No verification performed. (9) Transportation: No shipping documents. (10) Custody: Not disclosed. The non-current inventory classification under IFRS IAS 2 requires measurement at lower of cost and NRV — if NRV is $8K-$200K, a write-down from $15.8M is required. This matches documented Financely Group fraud pattern where 'applicants fail to provide any documentation to support the collateral: no SKR, no inspection certificate, no insurance slip, no warehouse receipt.'
EDGAR submissions review confirmed: No SEC UPLOAD (staff comment letter) or CORRESP (company response) filed after April 10, 2025 through March 24, 2026. The most recent SEC comment letter exchange was April 10, 2025 (UPLOAD accession 0000000000-25-003829, related to prior F-3 acceleration). The copper powder transaction (November-December 2025), the F-3 registration (February 2026), and the half-year financials with material weakness disclosure (March 13, 2026) have not prompted any SEC staff comment letters as of the investigation date. This is notable: the SEC has not publicly challenged the copper powder valuation or related disclosures through the comment letter process.
Full Timeline
16 events
Full Timeline
16 events- 1.Finding #6260
- 2.Finding #6251
- 3.Finding #6246
- 4.Finding #7558
- 5.Finding #6262
- 6.Finding #6273
- 7.Finding #6281
- 8.Finding #7560Sources: Alibaba showroom listings for 99.999% copper powderSource record, Chemical Store catalogSource record, Goodfellow copper powder groupSource record, Institut fuer Seltene Erden pricingSource record, MSE Supplies product listingsSource record, Sigma-Aldrich catalog 203122-10GSource record, powdermetallurgy.com industry dataSource record
- 9.Finding #7399
- 10.Finding #7543
- 11.Finding #7545
- 12.Finding #6269
- 13.Finding #6271
- 14.Finding #7554
- 15.Finding #6342
- 16.Finding #7569
- 17.Finding #7566
- 18.Finding #7562
- 19.Finding #7571
- 20.Finding #7565Sources: Financely Group 'Copper Powder Monetization Scam' articleSource record, Financely Group 'Ultra Fine Copper Powder The Phantom Collateral That Wont Stay Dead'Source record, Financely Group 'When Ultra-Fine Copper Powder Becomes a Pretext for Fraud' (MediumSource record, Financely Group 'Why Every Ultra Fine Copper Powder and Nickel Wire Deal is a Scam'Source record, Trade-metal.com listing 99.9997% copper powder 1kg at .6M matching fraud patternSource record
- 21.Finding #7384
- 22.Finding #7386
- 23.Finding #7393
- 24.Finding #7568
- 25.Finding #6346
- 26.Finding #7398
- 27.Finding #7542
- 28.Finding #7480
- 29.Finding #7476
- 30.Finding #7478
- 31.Finding #6268
- 32.Finding #7466Sources: MarketScreener marketscreener.com/quote/stock/CUFE-LTD-10357291/news/Fe-FEL-Acquires-Rights-to-Kasombo-Copper-Cobalt-Project-in-DRC-24743928/Source record, Proactive Investors proactiveinvestors.com.au/companies/news/180814/cape-lambert-resources-does-deal-with-fe-limited-180814.htmlSource record
- 33.Finding #7467Sources: AFP media release (May 2023Source record, BusinessNews.com.au Sage-Timis ASX blockSource record, FTBL Perth Glory salary capSource record, ICIJ Panama Papers databaseSource record, Proactive Investors Cape Lambert-FEL dealSource record, SEC EDGAR CRML filingsSource record, Wikipedia Tony SageSource record
- 34.Finding #6106Sources: https://www.criticalmetalscorp.com/critical-metals-corp-secures-us120000000-loi-for-a-15-year-term-loan-from-the-us-federal-government-bank-exim-bank-for-the-development-of-its-tanbreez-rare-earth-project-in-greenland/Open artifactSource record, https://www.csis.org/analysis/greenland-rare-earths-and-arctic-securityOpen artifactSource record
- 35.Finding #6264
- 36.Finding #6275
- 37.Finding #7561
- 38.Finding #7552
- 39.Finding #7541
- 40.Finding #7387Sources: https://www.sec.gov/edgar/search/#/q=CIK1951089%3AF3%3A20260223Open artifactSource record, CIK:1951089Open artifactSource record, https://www.sec.gov/edgar/search/#/q=CIK1951089%3AF3%3A20260318Open artifactSource record, https://www.sec.gov/edgar/search/#/q=CIK1951089%3ASC13D%3A20240305Open artifactSource record, https://www.sec.gov/edgar/search/#/q=CIK1951089%3ASC13G%3A20241016Open artifactSource record
- 41.Finding #6368
- 42.Finding #6240
- 43.Finding #6241
- 44.Finding #6248
- 45.Finding #6277
- 46.Finding #6245Sources: SAM XW4PVY32Q7K1Source record
- 47.Finding #6278
- 48.Finding #6261
- 49.Finding #6265
- 50.Finding #6267
- 51.Finding #6276
- 52.Finding #6272
- 53.Finding #6280
- 54.Finding #6270