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I an not sure that is binding on the company. Can you find a source for it in US securities law or SEC memo?





Sure, that refers to foreign issued equity securities listed on foreign exchanges as securities, not tokens claiming not to be securities


So once they realize they are securities this applies?

The main question is, are the exchanges considered foreign if the ICO is of a foreign company? How do you trade stuff if the securities are not transferrable?

Perhaps the ICOs don't pass the Howey test!




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