For the embryonic, novel and crazed ICO marketplace, Winter is coming. But not in its traditional form, rather in the form of a swift, steady and relentless U.S. Securities and Exchange Commission (“SEC”) dragnet.
For those scratching their heads, “Winter Is Coming” is the motto of House Stark, one of the Great Houses of Westeros in the HBO hit series Game of Thrones, and the meaning behind these words is one of warning and constant vigilance. The Starks, being the lords of the North, strive to always be prepared for the coming of Winter, which hits their lands the hardest.
Who should heed this warning? Issuers, promoters, facilitators, so-called “finders,” investment banks, law firms and anyone else connected to Internet Coin Offerings (“ICOs”), the method by which startups or other parties can issue cryptographic tokens in an effort to fund or bootstrap a new blockchain network. Because if not prepared, ICO curators, sponsors, affiliates and the rest might all find themselves caught in the SEC’s investigative, regulatory and prosecutorial crosshairs.
‘Enforcement 40’ for 2020
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