Month: November 2018

The Commission has frequently reiterated its view that initial coin offerings or ICOs may involve the sale of securities in the form of an investment contract based on the traditional Howey analysis. Early cases such as Munchee, settled in December …

Resolving an ICO-Security Offering – The Terms Have Changed Read More »

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The Commodity Futures Trading Commission’s Division of Enforcement published its annual report (here). Like the Report for the SEC’s Division of Enforcement, it outlines the priorities of the Division and its program. The Report also emphasizes that statistics in terms …

CFTC Enforcement Annual Report: Priorities, Organization, Statistics Read More »

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