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Expert Analysis

SEC's No-Action Letters Confer Utility Token Guidance

By Anthony Tu-Sekine and Kyle Swan (August 22, 2019, 4:01 PM EDT) -- It has been more than two years since the U.S. Securities and Exchange Commission issued its DAO report,[1] which warned that tokens and coins sold in initial coin offerings may be securities subject to federal securities laws. But one of the key problems exposed by the DAO report remains: how to offer a token so that it is not a security. ...

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