Barrocas selling into an open window
Transfers as discipline, not as mechanismYou have no trading windows and no Form 4s. But the principle generalises: he sold two days after the information was public, not two days before. For a private company the equivalent is the timing of a share redemption, a dividend, or a sale to a co-shareholder relative to information only you hold — where the duty is to your co-shareholders and the valuation, not to a regulator.
First step this weekIf any internal share transaction is contemplated in the next two quarters, write down what you know that the other side does not, and date it. That note is the whole of the discipline.