In just the last few months, the SEC has brought successful enforcement actions against EtherDelta, Paragon, Airfox, DJ Khaled and “Money” Mayweather himself, all predicated directly or indirectly on unregistered Initial Coin Offerings (“ICOs”). These settlements confirm that the SEC can and will target domestic ICOs for enforcement. But what about foreign ICOs? All those geo-fenced, “no Americans” ICOs that were launched in the last few years?
Disclaimer: This article is not intended as legal advice and does not establish an attorney-client relationship with any party.