You may be right TheWaitingGame, but I went back to the bridge financing done in 2019 (while Poet waited for the money from DenseLight sale).  Insiders took part of this financing even though it was not registered in the USA.  These things can be complicated, amendments could have been added to this financing, I really don't know. Just exploring if it could be the same with the present financing.

Here's the NR on april 1st 2019 : https://poet-technologies.com/news/2019-apr-1.html

"The securities referred to in this news release have not been, and will not be, registered under the United States Securities Act of 1933, as amended (the "U.S. Securities Act"), or any applicable securities laws of any state of the United States, and may not be offered or sold within the United States or to, or for the account or benefit of, U.S. persons (as such term is defined in Regulation S under the U.S. Securities Act) or persons in the United States unless registered under the U.S. Securities Act and any other applicable securities laws of the United States or an exemption from such registration requirements is available. This press release does not constitute an offer to sell or a solicitation of an offer to buy any of these securities within any jurisdiction, including the United States."

Poet management and IBK took 47% of the first tranche.

NR on april 4th 2019 : https://poet-technologies.com/news/2019-apr-4.html

"Insiders of the Company and IBK Capital subscribed for over 47% of the first tranche of Convertible Debentures, including all of the Company’s board of directors and senior management team."