Project administrative and subscription fees charged by the offering, government filing fees at the amounts in the USCIS fee schedule, Form G-1055, and professional fees for independent legal review, source-of-funds preparation and accounting. None of those count toward the qualifying capital.
Separate the investment from everything charged around it
The qualifying capital is one number; the cost of the exercise is another, and offerings do not always present them together. Project administrative fees are commonly charged on top of the investment and are not part of it. Government fees for the petition and later filings appear in the USCIS fee schedule, which should be consulted directly rather than quoted from memory.
Independent legal review is the expenditure most worth making and the one most often skipped, since the project's own counsel does not act for Rosalind. Source-of-funds preparation carries real accounting cost where a business history must be reconstructed. Finally, the capital must remain at risk, so it should not be budgeted as though it were a deposit; an arrangement guaranteeing its return would not qualify, and the possibility of losing it is part of the framework rather than a remote contingency.