Until September 30, 2019, Securities and Exchange Commission (“SEC”) enforcement actions in the crypto industry conveyed a consistent message: most crypto is a security, and if a token issuer does not follow the registration...more
10/18/2019
/ Blockchain ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Assets ,
Financial Industry Regulatory Authority (FINRA) ,
Penalties ,
Registration Requirement ,
Regulation A ,
Regulation D ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Regulation ,
Securities Violations ,
Settlement Offer ,
Token Sales
This white paper discusses considerations related to conducting a token offering under Regulation A under the Securities Act of 1933 (the “Securities Act”). The benefit of this strategy is that it can allow broad...more
10/2/2019
/ Blockchain ,
Cryptocurrency ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Howey ,
Initial Coin Offering (ICOs) ,
Initial Public Offering (IPO) ,
Offering Statements ,
Public Offerings ,
Regulation A ,
Reporting Requirements ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Token Sales ,
White Papers
In a recent article, we discussed why the Securities and Exchange Commission (“SEC”) and its staff (the “Staff”) continue to think most cryptocurrencies and other crypto assets (“tokens”) are securities at the time they are...more
Initial coin offerings (ICOs), token pre-sales, and similar sales of blockchain-based coins and tokens are quickly becoming an important fundraising option, and an important method of attempting to seed a token-based platform...more
In recent months, a variety of companies have considered "initial coin offerings" (ICOs) as a way to generate money for their businesses. Companies considering ICOs should be aware that, depending on the structure of the...more