Under any circumstance, by allowing their ICO clients to peddle unlawful securities and violate a broad range of securities laws, lawyers are failing in their role as gatekeepers. Moreover, by providing the kind of legal advice that can land a client into the SEC’s crosshairs, or even worse, into the crosshairs of criminal investigators and prosecutors, lawyers risk more than just their reputations and livelihoods. Per Chairman Jay Clayton, lawyers now also risk being investigated or prosecuted right beside their ICO clients.
‘Enforcement 40’ for 2020
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