Offer Closed SendGold (Mobile Asset Holdings Ltd)

SendGold: a digital money platform using gold (5:23 mins)

Crowdfunding Type of Offer
$250 Minimum Investment
$500,000 - $2,000,000 Size of Offer
$20.1 millionPre-money Valuation

Minimum Target $500,000




2% - 9%




Offer now closed. Please ensure applications are funded as soon as possible.


Please consider the offer document and general risk warning before investing.

Investors are entitled to a 5 day cooling-off period.

OnMarket's fees are a maximum of 6.5% of the funds raised, paid by the Company.

Investments over $10,000 are restricted to Sophisticated investors - Apply here


SendGold Investor call with CEO, Jodi Stanton and CTO, Alan Keenleside. recording available here

SendGold is pleased to announce that they are now live in South Africa, the country that produced half of the world’s gold. more here


SendGold is a peer-to-peer digital money platform which allows customers to save, send, pay or gift quickly and easily using gold.

  • Highly accessible, with two-minute self-service signup, no set-up costs, and no hidden fees
  • Customers are the outright individual owners of 99.95% pure physical gold bullion
  • Users can acquire and save their gold for investment or can send it as a payment or gift in any amount, anywhere in the world as easily as sending a text message
  • Gold is stored in high-security vaults in Australia and is insured against damage or theft by Lloyd’s of London
  • Successfully raised over $2.3 million from sophisticated and professional investors, including $900k in FY2018

SendGold is the trading name of Mobile Assets Pty Ltd, a 100% owned subsidiary of the issuer, Mobile Asset Holdings Limited.

Market Problem

SendGold believe a digital currency revolution has begun because the old money system needs an upgrade:

  • The monetary crisis that began in 2009 has cost over $15 trillion in banker bailouts and investor losses, but the system is not fixed. It still requires increasing quantities of new debt and is still based on bank currencies that buy less and less in goods and services every year
  • It still takes days to send funds to another country even though we have a global internet and 6 billion mobile phones in people’s hands around the world. There are 2 billion people left behind as they have no access to a bank account
  • When money does not hold its buying power, people must invest separately just to stay even. But unlike the wealthy who can afford to tie up the majority of their funds in investment assets that can appreciate in value, most people around the world need their funds to be liquid 24/7.

SendGold addresses each of these problems with their digital gold money platform. It is low-cost, global and peer-to-peer like Bitcoin but is instead based on a real asset.

SendGold: Based on Gold

  • SendGold is based on physical gold bullion because they believe gold is one of history’s most reliable investment assets
  • Long-term returns from gold also compare favourably with returns from other asset classes like equities and bonds, and since 2000 gold has even kept pace with Australian house prices.

Key Achievements

  • Version one SendGold app is currently live in nine countries in Asia Pacific, home to 43% of the world’s population, including Australia, India, China and Indonesia
  • Early traction and brand recognition via 7,000 app downloads and 170,000 Facebook followers
  • Fully-built platform based on bank-grade systems that is scalable, cloud-based, and third-party penetration tested
  • Full banking integration with payment providers including PayPal and Cambridge FX, enabling the sale of gold in over 140 currencies
  • Domiciled in Australia with compliant AML/CTF program monitored by AUSTRAC
  • Signed on large distribution partners in Rewards and Social Gaming
  • Developed and launched world-first “Gold-Rush”, a gamified customer acquisition tool that works like the Pokémon Go game but with real gold.

Gold Rush by SendGold

Market Opportunity

  • Aims to address the demand for simple investments and mobile payments across Asia Pacific and around the world
  • Targets increasingly wealthy APAC middle class (estimated US$3.3 trillion in new money for investment in the next decade) with an asset they understand and value
  • Operates in large, high-growth sectors including payments (US$2 trillion in provider revenues p.a.), mobile payments (growing at 33% YOY), cross-border remittances (US$540 billion p.a.), gold trading (US$200B per day), online gifting, social gaming, and rewards.

SendGold Product Roadmap

SendGold intend to grow the Company along several degrees of expansion: geography, hard assets, sectors and technology innovation:

Offer Overview

SendGold has a pre-money valuation of ~A$20.1 million having built the business to-date with founder’s funds and private investment rounds.  The Company is looking to raise a minimum of $500,000 and a maximum of $2,000,000 via this equity crowdfund offer (the Offer) at $0.50 per share. 

The funds raised will be predominately applied to:

  • Marketing & brand awareness
  • People & product development.

SendGold’s issued capital following the Offer is provided below:

Early Stage Innovation Company

The Company has assessed itself as a qualifying Early Stage Innovation Company (ESIC), and investors who purchase new shares in qualifying ESICs may be eligible for certain early stage tax incentives.

See the link to the ATO website under the Company Releases tab for more information.

Investor Rewards


SendGold is subject to a range of risks. While investors should consider all the risks before applying for shares, we recommend that investors take particular notice of the following:

Competition and new technologies risk – Competitors may have significant additional experience and/or resources to develop competing products which may adversely affect SendGold’s prospects.
Development risk – New products may be delayed in development, may not be capable of cost-effective commercialisation, or may not be supported or adopted by new or existing customers, affecting the Company’s prospects.
Gold Price risk – The Company may incur losses on unhedged gold amounts and may be adversely affected by a longer term or persistent fall in the global price of gold, making SendGold less attractive to customers.
Regulatory risk – Changes in applicable regulatory law such as licensing and reporting obligations could increase regulatory compliance costs and affect the Company’s ability to promote the Platform.
Customer adoption risk – If the Company fails in the execution of its marketing campaign, customer adoption, and business partnerships strategies, it may have an adverse impact on profitability.
Key man risk – If the Company cannot retain its key people, this may have a detrimental impact on the business.
Funding risk – If the Company requires further financing, there is no assurance that this can be obtained on favourable terms or at all, which may affect the Company’s ability to achieve its goals.

A more detailed discussion of risks facing the Company are set out in Section 2.17 of the Offer document.

Management and Board

SendGold has a highly experienced and capable Management and Board across technology, product, financial services and compliance. They bring a track record with top Wall Street firms, online institutional foreign exchange dealers, and risk management consultancies.

Jodi Stanton, Co-founder and CEO


  • 6 years financial risk and derivatives advisory with insurers Aetna and UNUM and on Wall Street with clients such as J.P. Morgan and Goldman Sachs
  • 10 years consulting to financial and technology companies, including with McKinsey & Company
  • Extensive experience investing in, building and leading technology businesses
  • Bachelors Mathematics, M.B.A. Yale University, former Actuary A.S.A, M.A.A.A.

Mark Pey, Co-founder, Director, Business Development & AML/CTF Compliance Officer


  • 10 years Institutional Asset Management, primarily J.P. Morgan
  • A founder of the first web-based institutional forex platform (Currenex), now the world’s third largest
  • 10 years in senior roles for Microsoft Corporation including Financial Services Industry Manager.

Alan Keenleside, Chief Technology Officer


  • 15 years of experience delivering technology for the Financial Markets covering Clearing and Settlement, Custody Operations and International Trading.
  • Former Head of Equity Technology at Bank of America Merrill Lynch
  • Helped deliver the Nabtrade international trading platform.

Steve Wilson, Chief Security Advisor


  • Recognised global expert in cybersecurity in financial services
  • Active contributor to numerous cybersecurity committees and industry programs
  • Consulted to Westpac, Australia Post, Australian Stock Exchange, Standard Chartered Bank Singapore
  • Nine patents for identity management technology.


The Offer is subject to a Maximum Subscription amount of $2,000,000. If the Maximum Subscription is reached, the Offer will close early. Applications will be treated on a time priority basis and may be subject to scale back, so please fund your application as soon as possible.


IMPORTANT: Please read the below information before investing in this Equity Crowdfunding offer.

RISK WARNING:  Crowd-sourced funding is risky. Issuers using this facility include new or rapidly growing ventures. Investment in these types of ventures is speculative and carries high risks. You may lose your entire investment, and you should be in a position to bear this risk without undue hardship. Even if the company is successful, the value of your investment and any return on the investment could be reduced if the company issues more shares. Your investment is unlikely to be liquid. This means you are unlikely to be able to sell your shares quickly or at all if you need the money or decide that this investment is not right for you.

Even though you have remedies for misleading statements in the replacement offer document or misconduct by the company, you may have difficulty recovering your money. There are rules for handling your money. However, if your money is handled inappropriately or the person operating this platform becomes insolvent, you may have difficulty recovering your money. Ask questions, read all information given carefully, and seek independent financial advice before committing yourself to any investment.

5 DAY COOLING OFF PERIOD: There is a 5 business day cooling off period for retail investors. During this period, you may withdraw your application and receive a full refund into your nominated refund account. Please note: After the 5 day cooling off period has expired, you will be unable to withdraw your application. More information here.

ONMARKET FEES: Upon successful completion of the Offer, a maximum fee of 6.5% of the funds raised will be paid to OnMarket by the Company.

ONMARKET INTERESTS: OnMarket and its associates will be participating in this offer.

ONMARKET INTERESTS AND AMOUNTS SUBJECT TO COOLING OFF: The funding bar displayed under each crowd funding offer may include applications where payments are yet to be made and amounts that are subject to the cooling off period.

Section 734(6) disclosure: The issuer of the securities is Mobile Asset Holdings Limited ACN 614 791 043. The securities to be issued are fully-paid ordinary shares. The disclosure document for the offer can be obtained by clicking on the link above. The offers of the securities are made in, or accompanied by, a copy of the disclosure document. Investors should consider the disclosure document in deciding whether to acquire the securities. Anyone who wants to acquire the securities will need to complete the application form that will be in or will accompany the disclosure document (which can be done via the electronic application form which will become available by clicking the bid button above).‚Äč


Question time

We'd love to answer your questions, we'll have one of the OnMarket team or the company representative of the offer get back to you asap. So ask away ...

Revenue streams

What are the revenue streams for this company?

A S Mohammad M (OnMarket member) on 22/08/2018

Thanks A S Mohammad,

We are a clip-of-the-ticket model typical of most financial services companies. Our revenue model is built on transaction fees, dealing spreads (gold margins), and later, minor storage fees. Our key value drivers are number and size of transactions, and to a lesser extent, gold float on the platform. This is true for our version one product and continues to apply across our product roadmap (shown above).

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to A S Mohammad M on 22/08/2018
Share registrar

Does the company plan to engage a share registrar & issue share certificates to all investors?

Ian H (OnMarket member) on 22/08/2018

Ian H,

Yes absolutely we are engaging a share registrar who will issue the share certificates to all investors.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Ian H on 22/08/2018

When can the share certificates be expected

Ron S (OnMarket member) replied to Jodi S on 19/09/2018

How do you differentiate SendGold from existing platforms like Bitgold/ Goldmoney which have been around longer?

Brian K (OnMarket member) on 22/08/2018

Thanks Brian,

We have included a direct comparison chart on page 23 of our offer document, which includes Goldmoney.

They also have a peer-to-peer, direct ownership model, but unlike Goldmoney, SendGold is a technology platform model, providing us with the ability to target adjacent market sectors which already include Loyalty and Gaming.

We are operating in some of the largest markets in the world, and in our view there will be multiple opportunities to grab market share, create new markets and provide a liquidity event for our investors.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Brian K on 22/08/2018
Future listing plans

Does the company have any plans to get a full ASX listing in the future via an IPO & if so what sort of timescale would that be in & what would it be dependent upon?

Ian H (OnMarket member) on 22/08/2018

Thanks Ian,

The company is very focussed on creating a liquidity event for shareholders. Over the last year we have been actively evaluating several vehicles in which to do this, including an IPO on the ASX. Acquisitions in the payments sector are common. PayPal, for example, has made four acquisitions in the last four months totalling USD 2.7 billion. In addition, there are mechanisms developing in the digital currency sector that may provide investor liquidity for SendGold.

As for timing, our goal is 18-24 months, dependent on both market conditions and company performance.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Ian H on 23/08/2018
Developing markets and Expat remittances

Similar to Peter H's question, I was hoping to invest a decent sum of money. I have gotten as far as dedicating my investment amount, however at the moment I am overseas without cell phone reception and therefore my account will not allow me to process this amount through to DC Power Co until after midnight tonight. Should I continue with this transaction after midnight, what would happen to my money? Will it become null and void? Bounce back to my account?
Any help you may be able to provide will be greatly appreciated.

Michael S (OnMarket member) on 23/08/2018

Thanks Michael,

Money sent home by migrants is one of the largest financial inflows to developing countries, with annual volumes exceeding $500 billion. Outbound remittances from Australia total more than $16 billion annually. The top 5 recipients include China, The Philippines, India, Vietnam and Lebanon. We are currently live in the first four, so even without a partner in those countries, Australian SendGold customers can send gold instantly to these countries and cash out in their local currency today. However, as a platform, we are beginning to work with more local partners across the region, and in particular, these four countries, to accelerate our growth through our Gold-as-a-Service.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Michael S on 23/08/2018

Thanks Jodi for your in depth response.

Michael S (OnMarket member) replied to Jodi S on 24/08/2018

First thanks for the opportunity to ask questions.

You are looking to extract value from a desire be associated with possession of gold, and to avoid unreliable value of crypto currency. Is that right?

Jack M (OnMarket member) on 23/08/2018

Thank you Jack,

Yes we believe gold is a proven store of value and possessing it has protected wealth for centuries. SendGold customers own 100% legal title to physical gold bullion. Weve turned gold back into money.

SendGold is peer-to-peer, instant, and global like crypto, but is based on a real asset that is simpler to understand, simpler to secure, and less volatile. Furthermore, SendGold delivers these benefits in a way that complies with global banking regulations.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Jack M on 23/08/2018

You mention games and PayPal I recall. Are you referring to SendGold as a method of payment?

Jack M (OnMarket member) on 23/08/2018

Certainly. Our retail app is a peer-to-peer method of payment. In addition, our Gold-as-a-Service embeds gold payments into third party platforms. We have signed and are busy launching customers in gaming and rewards and are also targeting neo-banks, e-wallets, and other high growth global sectors.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Jack M on 23/08/2018
User Entity

I have gold in your system. To send gold to someone else what information do you require of them? Do they need to sign up etc?

Jack M (OnMarket member) on 23/08/2018

I also missed the cut off as we have been away and wanting to know if we can still join.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Jack M on 23/08/2018

Is it possible to take delivery of gold physically?

Srinivasa Raja V (OnMarket member) on 23/08/2018

Thanks Raja,

Our value proposition is digital money, making gold liquid for savings, investment, payments and gifts, creating a network of global customers.

If we receive sufficient customer demand for physical redemptions we will certainly add that service as we have the architecture and the relationships to do so.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Srinivasa Raja V on 24/08/2018

Why is the purity of gold only 99.95% whereas gold bullion in Australia is 99.99% (24 ct)?

Srinivasa Raja V (OnMarket member) on 23/08/2018

Hi Raja,

We established .9995 as the minimum gold purity as that is the London Bullion Metals Association (LBMA) standard for good delivery bars, which have the deepest global physical gold markets and best prices.

We are currently buying .9999 purity gold in wholesale markets but have recently been approved for a dealing relationship with a Category 1 Ring Dealer at the London Metal Exchange (LME), which will provide us access to these deep markets and lower prices.

Regardless of bar purity, please note that we account for gold in your account at 100% purity, as this is industry standard.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Srinivasa Raja V on 24/08/2018
Equity Dilution

The risk statement says Even if the company is successful, the value of your investment and any return on the investment could be reduced if the company issues more shares..

Is there anything in the companies current equity structure or constitution that in your judgement is unusual when considering a shareholder who becomes a shareholder as a result of this current processes rights to prevent such a dilution?

Jack M (OnMarket member) on 24/08/2018


Mobile Asset Holdings has only ever issued one class of shares ordinary and only ordinary shares may be issued through this crowdfunding offer. We have a simple structure and there is nothing unusual in our constitution that would give anyone, including founders, non-dilution rights.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Jack M on 24/08/2018

Can I assume that early revenues are already being generated? Are there large expenditures needed to further scale up?

I really like the possibility of physical redemptions especially in regard to gifting.

Nolan A (OnMarket member) on 27/08/2018

Thanks Nolan,

Yes we can now drive revenues. We are growing both retail customer numbers and transaction volumes at over 20% per month, predominantly through word-of-mouth. We are also launching our new Gold-as-a-Service clients Global Reward Solutions and Golden Matrix Group across India, China and Australia in the coming weeks.

We are highly scalable, globally, with a declining retail customer acquisition cost well under $10 and a cloud-based infrastructure with Amazon Web Services. We will continue to build our team as we grow but the key use of funds will now be customer acquisition - both retail and our business Gold-as-a-Service.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Nolan A on 29/08/2018
Asset Backing

Hi Jodi

Is there full physical gold asset backing for investments received?

Given that redemptions are not being offered at this stage does that allow for issuing more investments than the gold in the vault. If yes, is that a material risk and is it rebalanced regularly?


Rajeev A (OnMarket member) on 29/08/2018

Thanks Rajeev,

We are not a claim to gold, or a derivative, or an ETF. When our customers buy from SendGold they become the individual outright owners of physical gold bullion. So in that sense SendGold is not asset-backed; it is the asset itself. Customer gold does not sit on our balance sheet and is not encumbered in any way.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Rajeev A on 29/08/2018

Thank you Jodi.

Rajeev A (OnMarket member) replied to Jodi S on 29/08/2018
Limitations on customer payments

The company is rolling out the product country by country & is currently in 9 countries. You stated that to receive gold from a sender you receive an email & then follow the link to setup an account to take ownership of the gold someone is sending you.
Does that mean that you can only send gold to people in those 9 countries?
Other competitors may not take the same country by country approach & 'go global', all be it without the same level of accreditation. Is there not a danger that by only targeting selected countries that a competitor will be become the 'go to gold platform' in a situation where first mover is often the critical factor in whether a company suceeds or fails?
For instance if you couldn't send money to someone in the US via Paypal it most certainly would not have succeeded & someone else would have taken that premise, improved on it & become 'Paypal' instead.

Ian H (OnMarket member) on 30/08/2018

Thanks Ian,

We have spent 3 years on compliance, legal, tax and equally as challenging, banking integration. The peer-to-peer capability put many hurdles in front of us, but is now our key market differentiator (along with other things like direct asset ownership and our platform strategy).

We are approved today to accept customers from any country not under financial sanctions (like Iran and North Korea for example). It was prudent for us to focus our initial resources on the high-volume Asian-Pacific corridor, but funding will allow us to go global. You may have seen from our rollout map on page 15 in our offer document that we originally intended to be in the US, Canada, South Africa, South America and Eastern Europe by 1Q 2019. However, we are 3 months ahead of schedule. We will be live in South Africa next week and North America in 4Q 2018.

In short, we are able to go live globally and have ticked off the boxes of tax, legal, compliance and banking integration to do so. Global expansion is what this crowdfunding is all about. While only Australian retail investors can participate, weve had interest from over 20 countries, building our brand awareness.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Ian H on 30/08/2018
Potential Risks


What are your top three risks apart from technology and funding? How do you expect to manage these effectively over your competitors in this space? Thanks.

Trevor S (OnMarket member) on 30/08/2018

Thanks Trevor,

The key risk is customer adoption. As an investor I was always taught that a good product in a large market is better than a great product in a small market. First, our opportunity is global, and second, we are targeting not only the highly traded gold market but other large and/or growing markets including mobile payments, gaming, neo-banks, loyalty, remittances, and online gifting. So we have a large market and we have a great product, which we are improving upon further with our new app to be released in 4Q.

To date our actual retail customer acquisition cost is a fraction of our plan, and our business model specifically drives this even lower with our customer acquisition game/tool Gold Rush and our Gold-as-a-Service, which can reach millions of retail customers with each business customer.

Digital money is potentially the lifeblood of future global commerce, and we share in the industrys optimism about the size and scale of the global digital currency market opportunity.

For our detailed view on risk and our mitigation thereof, please see page 37 of our offer document. But in general, we've taken a low-risk asset (gold), with a low-risk regulatory path (versus blockchain), in a business model that has been proven overseas, and applied it using a proven technology into some of the worlds largest markets.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Trevor S on 30/08/2018

I used the front end and would say in regard to adoption that I think the P2P liquidity is attractive. You mentioned Diwali and the Chinese New year in reply to a query below, add Christmas to that and gifting gold seems to be an attractive option, amongst all other advantages like a really good way to save in a proven asset or being able to use micro payments particularly for retail. It takes out the stress and the time spend in first trying to choose presents and then making an effort to buy those presents. Just a comment, seems a great model, self compounding in my opinion!

Rajeev A (OnMarket member) replied to Jodi S on 31/08/2018

CEO/Directors- what is their equity holding? Philip Jacobson

Philip J (OnMarket member) on 30/08/2018

Hi Philip

Together the 4 directors own 74% prior to the completion of this round. If our maximum is raised this will be reduced to 67%.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Philip J on 30/08/2018
Profit and Loss

According to your current P&L statement ending 2017/2018 you are operating at a loss albeit lower than the previous financial year. When do you think you are going to make profit?

Eki B (OnMarket member) on 30/08/2018

Hi Eki,

We are very focused on our profitability milestone and we know how to run a lean company. We intend to get there within 5-7 quarters. We are launching our first two Gold-as-a-Service (GaaS) clients now, with reach to millions of customers in 4Q. We also have two important holidays coming up to drive both retail and GaaS transactions. Diwali is the Indian New Year celebrated in November. Indians traditionally acquire gold the day before Diwali. And Chinese New Year is in February. We are busy getting ready to release our new apps to take advantage of these.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Eki B on 31/08/2018
Spreads and gold price

Gday Jodi,
Do you have any idea of what the spread price/percentage might be when selling gold?
I also just set up an account with SendGold and had a look at what I can get for my money, at the moment if I deposit $55.28 AUD I get 1g of gold which is great however the current gold price listed with Australian Bullion Company in Melbourne is $58.49/gram. How is that possible/profitable?


Richard L (OnMarket member) on 31/08/2018

Hi there Richard,

We buy in bulk from wholesale gold dealers and add a mark-up. You can see the spreads in our Terms of Use:

Unlike most retail dealers we do not charge an additional premium for small purchases given our business model.

When you buy 1 gram you are buying title to a portion of the larger bars we buy. You are then the outright individual owner of 1 gram of gold, just like with the retail gold dealers.

SendGold is certainly a cost-effective way to own gold, particularly for retail investors. And of course it is also liquid for peer-to-peer transactions.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Richard L on 31/08/2018
Gold held currently

Hi Jodi

How much gold is currently in the vault, owned by SendGold customers? How has that grown in the last year?

I really think this business sounds like it's going places. I'm very impressed. Best wishes.

Mark D (OnMarket member) on 05/09/2018

Thank you Mark,

As digital money, our business is all about transaction volume, including purchases, sales, gifts, remittances and later, merchant payments, through both retail and our business Gold-as-a-Service customers. We are not a fund where we charge fees on assets under management (AUM).

Its transaction volume and the velocity of our digital gold money that matters. This also holds true through our product roadmap across our new channels such as neo-banks and our API feed to offer an asset-based cryptocurrency stablecoin. But to give you a sense of where we are sitting today we had $90k in transactions last month and weve been growing over 20% in both transaction volumes and customers each month with just a total of $40k spent to date on promotions and advertising. We have yet to reach our first million dollars in a current gold float, but aim to do so early in 2019. But again, this KPI is far less important than transaction volume. The purpose of this round and future rounds is predominantly for marketing and advertising to drive transaction volume.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Mark D on 06/09/2018

Thank you Jodie. I'm looking forward to being a part of this business well into the future.

Mark D (OnMarket member) replied to Jodi S on 06/09/2018
How does SendGold compare to Glint in the UK?

How does SendGold compare to Glint in the UK?

Michael S (OnMarket member) on 06/09/2018

Hi Michael,

UK-based Glint is also an early stage fintech that offers digital gold ownership. They just raised AUD3M at a AUD78M valuation through crowdfunding. (Crowdfunding is far more advanced/popular in the UK as licenses were just granted in January 2018 in Australia so were catching up.)

We are importantly very different from Glint in both infrastructure and ownership rights, which we believe makes SendGold more of a platform than a product, and provides us with significantly more growth opportunity.

1. Prepaid card Infrastructure:

Glint have based their system on prepaid card infrastructure. This potentially gives them an immediate ability to spend from a gold account at merchants, but comes with significant real world business limitations.

We at SendGold also considered this approach early on but decided it would drastically limit our market opportunities. Card schemes for example may not permit peer-to-peer transfers, which Glint does not offer. Card scheme coverage rules may also limit the countries in which Glint may operate. They are available to UK and EEC residents only. SendGold has no such limitations.

SendGolds core recordkeeping system is fully independent of our banking and card scheme partners. This allows us the freedom to pursue market opportunities from gaming to loyalty to M-commerce without worrying about whether these might violate the card scheme rules on prepaid debit cards, either initially or at a later date.

2. Encumbered Gold:

Glints prepaid card infrastructure would also adversely change a customers ownership rights to the gold they hold as compared to a SendGold account.

Holding gold in a prepaid debit account also means that gold is encumbered by the card scheme as credit collateral against future purchases. The customer no longer has full outright ownership rights to their gold in their account, which is a fundamental differentiator of SendGold, and where we have spent significant resources to date.

Glint also encourages customers to hold gold in a second account type which appears to be a Contract For Difference (CFD) structure. In this case the customer would only have the right to the gold price, they would not actually own gold. This introduces counterparty risk where we believe none should exist: thats the point of outright ownership of audited, insured physical metal with SendGold. Glints CFD account structure would also impose securities licensing, registration, onboarding, disclosure, and customer suitability requirements.

SendGold architecture also enables us to offer merchant spend through card scheme merchants like Glint does, but we intend to do so through a partnership with a company that interrupts the payment authorization message from the POS at the network switch level. Merchant settlements then happen per normal card scheme processes, but the process is a pay-as-you-go-with-gold process, not a restrictive ongoing encumbering of the customers gold that introduces multiple additional business and counterparty risks.

We were strategic and deliberate in our platform and compliance design, admittedly taking long way around to get to where we are today. But we believe we now have important sustainable advantages with which to scale quickly.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Michael S on 06/09/2018

Apologies for the typos but when I cut and paste into the tiny screen the CMS does not capture any apostrophes.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Jodi S on 06/09/2018
Comparison with other blockchain gold start-ups

You have stated that you have decided not to use blockchain technology at the present. Nevertheless, there are a number of other global start ups who are proposing a similar gold/silver payment service using blockchain tokens, eg:
Why is your product offering better?
What blockchains did you evaluate before you decided to use your more traditional approach?

Simon C (OnMarket member) on 10/09/2018

Hi Simon,

Yes we also began 100% in blockchain. It was/is all very exciting, and seemed to make sense, at least before we spent 3 years looking at nothing else. It was potentially the answer to so many of our money system failures and growing counterparty risk issues and I personally became very passionate about its possible application.

Starting in 2013 we performed a comprehensive R&D covering substantially all new blockchain technologies including BTC, NEO, LTC, XRP, NXT, XCP, USDT, EOS, ETH, etc. We have owned and tested all major currencies against architecture, issuance, governance, security, cryptography, dealing, market making, liquidity, distribution, usage, sustainability, legal, compliance & taxation. We ended up putting our first live version of SendGold on Ripple back in 2015.

But we were too early, and we feel it is still too early. The land grab is on between platforms, and we believe many, many investors will lose millions of dollars in the process.

On page 23 of our offer document we mention digix in our comparison chart, to represent blockchain offerings at this time. We believe they and others will struggle in the medium term.

At the moment we are strategically blockchain platform agnostic through our Gold-as-a-Service APIs. In addition to the compliance issues:
- Blockchains have proven to be much less immutable than advertised, with planned and unplanned forks.
- Blockchains that are not immutable are still very slow and very expensive databases to operate.
- And that blockchain transparency comes with very high security risk; Tencent last week said by their estimates blockchain hacks had cost $2B already this year.

Since 2013 we have continued to evaluate platforms, and we now know what we are looking for to compete on a global scale with a peer-to-peer digital money platform. Our strategy is not to join the land grab imperative of the distributed ledger backbone itself, but to wait until both compliance and technology meet our standards. But as a platform, I can tell you that we intend to provide a blockchain gold token that can be held inside any of the major wallet architectures. At the moment we have several blockchain platform discussions in play (and none of them are limited to gold).

SendGold, in contrast to existing blockchain gold offers, is currently earning revenues, is fully integrated and compliant with the global financial services regulation, is secured, and offers 100% title to physical gold, regulated by some of the strongest property rights in the world. And moving forward we are positioned well to provide "shovels to miners" so to speak, through its gold tokenisation to blockchain platforms.

From our Chief of Security Steve Wilson, "We didn't feel that the Wild West of blockchain was the best way to protect people. Blockchain is very effective for purely digital assets, but it's also very volatile and difficult to secure. We think that we have solved the problem using fairly conventional technology, which is very mature, very conventional and therefore very reliable."

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Simon C on 10/09/2018

This article might be of interest:

According to Ms Stanton, blockchain was designed for digital assets, and any tangible asset-based currency, whether a hybrid cryptocurrency or simply digital like SendGold, are unavoidably more centralised than purely digital alternatives because of the centralised management of the underlying assets.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Jodi S on 10/09/2018

Hi again

Thank you for this extensive reply. There is a lot of hype around blockchain, and while the technology has great potential, many applications are more suitable for a regular database rather than a distributed ledger database. It seems you have come to that conclusion for the moment. In terms of your ongoing exploration of blockchain technology, can you explain further your comment "we are positioned well to provide "shovels to miners" so to speak, through its gold tokenisation to blockchain platforms", please?

Simon C (OnMarket member) replied to Jodi S on 12/09/2018


Sorry Simon I missed this follow up question yesterday.

Our Gold-as-a-Service APIs are designed to enable transfer of gold asset ownership into a wide variety of platforms such as loyalty, games, neo-banks and messaging. Given this design, we are able to view blockchain as another platform in this sense and continue our extensive work on both technology and compliance. Inter-operability is key, and the risk of assets being "orphaned" on chains that are superseded by new innovation is high (although atomic cross-chain swaps can mitigate this). Without going into the detail, the solution for a SendGold hybrid product is not simply black or white given our assets (eg. gold) are not digital. There is currently a land grab from platforms, as these platforms often need 'content' to use their 'pipes', as the mobile telephony companies needed user content to move through their spectrum years ago. We will select platform and partner only when the technology has matured.

But emphatically, we will not compromise our non-blockchain core platform that we have spent years building, securing and making globally compliant. We believe this is where we will create tangible shareholder value in the short and medium term.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Simon C on 13/09/2018
Managing expropriation risk

How do you propose to manage the risk of gold expropriation in the event of a major financial crisis? In particular, how would the application of Part IV of the Banking Act 1959 - if brought into force - affect your customer holdings and your operation?

Simon C (OnMarket member) on 10/09/2018

Simon, we would not offer legal comment here, except to say that in this extreme scenario, we would be regulated in the same way as other Australian gold dealers.

SendGold has been strategically domiciled in Australia given Australia has strong financial and consumer protection laws, which we believe are well recognised across Asia. The independent international Property Rights Alliance gives Australia one of the highest scores in the world (8.24) for its property rights protections. By comparison, the United States receives a score of 8.07, Germany a score of 7.95, China a score of 5.71, and India a score of 5.56.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Simon C on 10/09/2018

Hi again

I asked this question because several commentators have raised this concern about allocated gold at one of Australia's longest established gold refining & storage facilities, the Perth Mint. Since holding gold is a way to hedge against the risk of bank failures in a financial crisis, the sovereign risk of government expropriation is relevant for your gold-backed operation. Bullion vaults in countries such as Switzerland and Singapore highlight their low expropriation risks. Interestingly these two countries score higher (8.618 and 8.404 respectively) in the 2018 IPRI assessment. Furthermore a number of your global competitors (eg GoldMoney) seem to offer storage options in these & other jurisdictions. This does make me wonder why you are proposing to put all the (golden) eggs in one (Australian) basket.

Simon C (OnMarket member) replied to Jodi S on 12/09/2018

With our Category 1 Ring Dealer we will be able to custody gold in both Singapore and Swiss jurisdictions for those customers who prefer this as some certainly do, and as you suggest it could mitigate our risk even further. Yes SGP also has strong property right protections, especially compared to our target markets such as China and India, where property rights are weak. It just does not make sense just yet to incur these additional costs.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Simon C on 13/09/2018
The source of revenue

Hi Jodi,

How do your shareholders get benefit from your platform transaction fees and other incomes?
I mean, on top of their gold share at the beginning of buying shares, they should get dividend from company platform income. Are the shareholders dividends paid in gold and added to their initial gold amount?
Thank You

habib m (OnMarket member) on 10/09/2018

Hi Habib,

Thank you for the suggestion. We can certainly pay dividends in gold for those who choose this option.

Related to this we have been approached by a gold company who wishes to pay its dividends in gold and has historically found the process full of complexity. SendGold explicitly simplifies this process.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to habib m on 10/09/2018
Ownership of gold

In the unhappy event that Sendgold went bankrupt, would customers be able to make full claim for the value of the physical gold, or would the gold we purchased through Sendgold disappear with the company? I understand our shares in Sendgold could become worthless, but what about the gold purchases? Thank you.

Nolan A (OnMarket member) on 11/09/2018

Thanks Nolan,

A very important question. We have prioritised this issue in our product design.

When our customers buy from SendGold they become the individual outright owners of physical gold bullion. So in that sense SendGold is not asset-backed; it is the asset itself. Customer gold does not sit on our balance sheet and is not encumbered in any way.

This means that in the unhappy event of SendGold having to cease operations our customers would be able to retrieve their gold value through the companys liquidator. The quantity of gold they individually own would not have changed. We are currently working with third parties to make that process fully transparent to our customers.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Nolan A on 12/09/2018
End date

Hi Jodi

Is there a possibility that this offer will be extended beyond Fri if the min 500k is achieved?

Kind regards

Rajeev A (OnMarket member) on 12/09/2018

Hi Rajeev,

We have raised over $2m to date from sophisticated investors and will continue discussions a that level. This CSF is in support of building our brand awareness, and allows retail investors participate. This offer at this price must close at midnight on Friday. Future funding offers are likely to exclude retail investors.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Rajeev A on 12/09/2018

Thank you Jodi.

Rajeev A (OnMarket member) replied to Jodi S on 12/09/2018
End Date

Hi, in relation to the previous question, could you clarify the answer? Will the monies be retuned if 500k is not raised via crowdfunding OR will shares be issued because you had raised 2m from other sophisticated investors?

Srinivasa Raja V (OnMarket member) on 13/09/2018

Hi Srinivasa - Our minimum in this CSF round is $500k. If we do not reach that goal by midnight tomorrow (Friday) 100% of the funds committed through OnMarket's platform will be immediately returned. At that point we will raise funds from wholesale investors only - as a new/separate round.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Srinivasa Raja V on 13/09/2018
Additional pre-IPO funding

Congratulations on reaching the minimum crowdfunding target!
Will SendGold have sufficient funding now to be able to reach it's pre-IPO targets? If not would you be open to investors who took part in the Crowdfunding being able to participate in further off market funding rounds?

Ian H (OnMarket member) on 14/09/2018

Thanks Ian,

We tend to close funding rounds every 6-9 months. This is our 6th round. We cannot comment now on what our next round looks like as we have many discussions underway. You may realise also that our next round will likely be at a higher valuation.

Jodi S (SendGold (Mobile Asset Holdings Ltd) representative) replied to Ian H on 14/09/2018

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SendGold (Mobile Asset Holdings Ltd)

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SendGold is a peer-to-peer digital money platform allowing customers to save, send or gift using gold as money. SendGold is highly accessible and is live in 9 countries, including some of the largest, fastest growing regions in the Asia-Pacific. With no set-up cost, no hidden fees, no purchase minimums, and with the long-term buying power of one of history’s most reliable, heavily traded assets, SendGold gives old money systems an upgrade.  


Before investing please consider the offer document and the general risk warning.

Minimum Target $500,000




2% - 9%