The SEC's Non-Guideline Guidance on Coin Enforcement

The SEC started to bring its first set of enforcement actions with a number of coin-related projects in late 2018, only months after Bill Hinman's speech. What followed over the next year was a wide range of weird settlements, which failed to serve as a deterrent to further ICO issuance. EOS, for example, which advertised its product on a giant Times Square billboard during consensus 2017 and raised north of $4 billion in crypto, is somehow allowed to skate by paying a $24 million fine. Other projects were not so lucky. Kick interactive, telegram and ripple labs launched absolutely gargantuan ICOs. Both kick and telegram lost badly in federal court, and I do not rate