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ICO publishes update report on use of personal data by adtech sector

The UK’s Information Commissioners Office (ICO) has published its update report into adtech and real-time bidding (RTB). 

The update clarifies the ICO’s views on adtech, specifically the use of personal data in RTB, and its intended next steps. It found that although many RTB players impose some controls on the processing and sharing of data, there are significantly different levels of engagement and understanding of how data protection law applies. 

The ICO’s initial investigations have raised several concerns with RTB data protection practices, with the ICO prioritising the areas of transparency & control, and the data supply chain. It found that methods of obtaining consent for the processing of personal data in RTB are often insufficient in respect of data protection law requirements; and that privacy notices issued to individuals lack clarity and fail to provide full visibility of what happens to their data. The ICO also found that the scale of the creation and sharing of personal data profiles in RTB is disproportionate, unfair and intrusive, especially as in many cases people are not aware that their personal data is being processed.

In response, the Open Rights Group (ORG) called on the ICO to take immediate action against companies that are unlawfully processing personal data. It expressed concern that the ICO was proceeding very slowly and cautiously, despite agreeing in substance with a complaint filed by the ORG ad Dr Michael Veale about the insecurity of adtech data sharing. 

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ICO Decision On Ministry Of National Security

The Information Commissioner Gitanjali Gutierrez issued a decision regarding an “internal review decision by the Ministry of National Security to deny a request under the Public Access to Information [PATI] Act 2010 on the grounds that the record did not exist.

“In Decision 15/2019, the requester sought email records of the former Permanent Secretary for the Ministry related to drug reform in Bermuda,” a spokesperson said.

“The requester sought an Information Commissioner’s review of the Ministry’s decision to administratively deny the request because the records did not exist. During the Information Commissioner’s review, the Ministry agreed to conduct additional searches and was able to locate responsive records.

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“The Information Commissioner has found that the Ministry incorrectly relied upon the administrative denial in section 16[1][a] of the PATI Act and has required the Ministry to process the records responsive to the PATI request and issue a new initial decision denying or granting access to the records in accordance with the PATI Act within six weeks.

“The Information Commissioner has also expressed her appreciation to the Ministry and the Applicant for their cooperation during this review.”

A full version of Decision 15/2019 follows below [PDF here]:

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Over $200m in a Day: How Facebook Used a Security Token to Fund the Libra Association

Facebook and its partners have recently launched the Libra Association, marking the largest security token sale in history. Take a look at just what this means for the world of blockchain and digital assets. 

Read more Security Token News pieces here.


On Tuesday 18th June, Facebook, along with 28 partners from diverse industries, unveiled plans to launch Libra: a new currency and payment mechanism based on blockchain technology. Described as “a simple global currency and financial infrastructure that empowers billions of people,” Facebook, as well as its partners, is bringing cryptocurrency to almost a quarter of the planet.

The news has been met with both celebration and some angst in both crypto community and traditional markets, with commentary alternating between anticipation at broader adoption of digital assets and fears over the privatization of money.  

In all of the excitement, many have missed the fact Libra has chosen to raise its funding for its foundation by issuing a security token, or the “Libra Investment Token (LIT)”, as they call it. With the Libra Association receiving over $200 million dollars, this issuance represents a meaningful step in the institutional adoption of security tokens.

About Libra

A not-for-profit organization based in Switzerland, the Libra Association, will have various layers of governance, compliance, privacy and data storage in order to ensure the protection of all members and investors. The most powerful of these is a council, similar to that of traditional shareholders.

“The council delegates many of its executive powers to the association’s management but retains authority to override delegated decisions and keep key decisions to itself, with the most important ones requiring a greater than two-thirds supermajority,” in a statement released on the Libra Association’s website.

In order to become a member, there are certain criteria which have to be met to be accepted. A business must be on the list such as the Fortune 500, S&P Global 1200 or FTSE EU30. Businesses must purchase a minimum of $10 million Libra Investment Tokens (LIT), and each $10 million invested gives the member one vote in the council.

Of course, investing this $10 million in security tokens does not go unrewarded. The Libra Association members will have access to the Libra Reserve when it is fully operational. This will mean that once the expenses of the association have been covered these investors will receive a dividend via the Libra Investment Token (LIT) for their early stage contribution. Much the same as a dividend stock but in a tokenised form, Facebook and the Libra Association will be setting up arguably the largest security token to date.

Mastercard, Andreessen Horowitz, eBay, Uber and Spotify all make up some of the original 28 partners, with the foundation receiving over $200 million thus far. However, there is expected to be no limit on the number of partners who wish to sign. By creating the Libra Foundation, Facebook and its members hope to regulate the underlying Libra currency. In a quote from the association’s page, it states that Libra members will play additional roles in order to achieve success.

“In these early years of the Libra network, there are additional roles that need to be performed by the association: … the raising of funds from the members as well as other investors through the sale of Libra Investment Tokens (a token that grants rights to a share of the future interest accumulated in the Libra Reserve.”

By doing so, Facebook has not only shown 28 of these behemoth businesses that the STO model can work, but it also opens up the possibility of more STOs coming to fruition of the back of Libra’s success. In short, Facebook has just signed some of the largest global corporations up to the security token model.

Significant Progress towards Mass Adoption

Libra’s decision to fund the Libra Foundation with a security token is an excellent development for the space.

As it stands, the LIT will become one of the most successful security tokens to date. And with no cut-off point for members joining, there is no limit to how many more LITs could be sold. In doing so, Libra is introducing a wide variety of very successful businesses to security tokens and the blockchain-based infrastructure.  

Now that some of the largest brands and names in the world have “dipped their toe in the water”, we believe many businesses will follow suit.  Libra will be a very successful showcase for the security token framework, which in turn will highlight their efficiencies and benefits.

For us at TokenMarket, it marks an extremely exciting time. Having been passionately involved in the STO space for a long time, we look forward to Libra complementing our efforts to promote security tokens.  The Libra Association may not know it, but they’ve just verified the possibility of a simple idea transforming into a multibillion-dollar industry. We for one, are excited to be a part of it.

Source: TokenMarket News
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ICO Decision On Health Department/PATI

Information Commissioner Gitanjali Gutierrez issued Decision 14/2019, which “concerns the Department of Health’s failure to issue an internal review decision within the statutory timeframes under the Public Access to Information [PATI] Act 2010.”

“In Decision 14/2019, the requester sought records related to day care centres and child care providers in two separate but related PATI requests,” a spokesperson said.

“The requester sought an internal review of the initial decisions on the requests. The Department outlined a number of administrative and logistical challenges it faced in issuing an internal review decision. The Department also explained that it had remained in communication with the requester throughout, including issuing an ‘interim internal review decision’.

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“The Information Commissioner has commended the Department for its intentions and efforts to disclose the responsive records. The Information Commissioner has acknowledged the challenges public authorities may face in processing PATI requests and that the Minister’s practice code on the administration of the PATI Act will hopefully provide such support when published.

“The Information Commissioner has noted, however, that the timeframes set forth in the PATI Act are designed to support the public’s right to access non-exempt records.

“The Information Commissioner has clarified that there is no provision in the PATI Act for ‘interim decisions’ and such decisions can cause confusion for the requester concerning the process to be followed, which may undermine the requester’s right to an independent review by the Information Commissioner.

“The Information Commissioner has found that the Department failed to issue an internal review decision within the statutory timeframes. The Department, however, issued both internal review decision during the review and the Information Commissioner has not required the Department to take any further action in relation to the Decision.”

A full version of Decision 14/2019 follows below [PDF here]:

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Deutsche Bank ‘bad bank’ not enough to address brand equity


Deutsche Bank ‘bad bank’ not enough to address brand equity – Global Investing Today – EIN News

























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ICO joins UK Regulators Network as full member

The UK Information Commissioner’s Office (ICO) has joined the UK Regulators Network (UKRN) as a full member. This association brings together regulators from the utility, transport and financial sectors. 

Membership of the UKRN will allow the ICO to co-operate with the main regulators in the UK on specific issues, such as cyber security. 

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Breaking Down the Jargon: The Impact of Regulatory Licences on Blockchain

Licences can be confusing. Here we take a look at just what TokenMarket’s individual licences mean for the business, as well as why they set us apart from others in the industry

Read more TokenMarket Update pieces here.


At TokenMarket, our mission is to provide all types of investors access to the next generation of rapid growth companies at a much earlier stage compared to traditional financing models. Transparency for us, like blockchain, is one of our founding principles. As of late, we realised there is a lot of white noise when it comes to regulation in the digital asset space. “We are regulated by this jurisdiction with this license which means we are able to…” It is confusing, to say the least.

This comprehensive guide is designed to outline why TokenMarket is pursuing licenses in these various jurisdictions, and in what way they help achieve our mission within the blockchain ecosystem. Of course, there are various different licenses in each jurisdiction so we have described each by the country for ease.

Gibraltar

The ICO boom in 2016 and 2017 brought a lot of bad actors into the crypto space as they tried to financially capitalise quickly. As a result country’s like Gibraltar wanted to provide trusted third party verification of these companies. This, in turn, allowed users to have an added layer of trust to businesses which had been rigorously checked and verified.

The result of this need within Gibraltar is the Distributed Ledger Technology (DLT) Licence which was the earliest “blockchain” licence available in Europe. TokenMarket Ltd (TML) is incorporated in Gibraltar and was one of the first businesses globally to have received “In-Principle” approval as a DLT provider.

This licence allows TokenMarket to make use of DLT for storing or transmitting value belonging to others but more importantly allows TokenMarket to ensure it is being held to a higher standard than others on the market.

You can read more about the nine principles here

Dubai

TokenMarket Capital Limited (TMCL), a fully owned subsidiary of TokenMarket Limited (Gibraltar), has recently been granted an “Innovation Testing License” (ITL) by the Dubai Financial Services Authority (DFSA).

The ITL allows TokenMarket Capital Limited to operate as a Category 4 Advisor/Arranger for issuers of/investors in Security Token Offers in or from the Dubai International Financial Centre (DIFC) for the duration of the ITL. TokenMarket expects the ITL restrictions to be lifted following “graduation” from the ITL. This is just the first step of our two-phase entry into the United Arab Emirates and the region.

The second, and main phase is to establish a DFSA-licensed and regulated Authorized Market Institution in order to operate a Tokenized Securities Exchange in or from the DIFC (the “Exchange”). The proposed Exchange remains the cornerstone of TokenMarket Group’s strategy and an integral part of its overall business plan. Therefore, we remain fully committed to working with the DFSA to obtain the necessary licenses and authorizations in order to achieve the plan we set out for the DIFC.

Given the recent and positive developments in the TokenMarket Group, we can now allocate additional resources to this project (as necessary) and hire dedicated teams to manage the Exchange’s license application process and to efficiently implement our strategy for the United Arab Emirates. Our firm target is to submit our final license application for the Exchange no later than September 30th, 2019.

UK

TokenMarket Technologies Ltd (TMT), the UK wholly owned subsidiary of TokenMarket Ltd (TML), was accepted into the Financial Conduct Authority’s (FCA) Sandbox, allowing TokenMarket to test its equity crowdfunding platform via tokenised securities. TMT will have a restricted licence to arrange transactions in securities for its first security token offering (STO) and will aim to get the restrictions lifted.

TokenMarket is allowed to raise up to £2 million whilst in the FCA Sandbox and the eventually unrestrictedly authorised TokenMarket Platform will allow issuers to raise up to €8 million without a prospectus by selling securities to investors including to “Everyday Investors”. Broadly, anyone can become an Everyday Investor. The Investor just needs to agree, by self-certification, to invest no more than 10% of their assets into company shares, bonds, funds or any other securities which are not listed or sold on a stock exchange.

This license, in short, allows TokenMarket to issue securities in a tokenised form and gives investors the ability to purchase equity in startups via blockchain. Thus, the benefits of blockchain such as instant settlement, ownership of assets and, once the third-party infrastructure for trading comes to fruition, 24/7 markets, can be matched with protections that owning equity in a business and regulated markets bring.

Malta

In a similar approach taken in Dubai, TokenMarket Limited are looking to secure two licences for trading and issuing of tokenised securities. The Malta licences are paired with the UK to allow the trading of tokenised securities across Europe. In Malta, however, there is one licence for the trading of utility tokens and a second for the trading of security tokens.

TokenMarket Ltd (TMM), the Maltese wholly owned subsidiary of the Gibraltan TokenMarket Ltd (TML), has been grandfathered as a Class 4 VFA Service Provider under the Virtual Financial Assets Act of Malta under which TMM has launched its Virtual Financial Assets (VFA), for example, utility token, exchange. TokenMarket will now submit its application for a full licence.

The VFA Service Provider licence does not allow TokenMarket to list securities on its exchange. TokenMarket is in the process of preparing its application for a Markets in Financial Instruments Directive (MiFID) a broker/dealer licence and a multilateral trading facility in Malta, which will allow it to launch a security token exchange using the technology of its VFA exchange.

Final Thoughts

In a market as quick moving as blockchain and fin-tech, regulation can be frustrating in its relatively slow speed. This is why TokenMarket has been working within several jurisdictions to marry the two for over 18 months now.

Ultimately this will be of benefit to our users and to the blockchain ecosystem, ensuring that protection and trust can be had from every player in the ecosystem.

Understanding the benefits of regulation and working alongside the regulatory bodies, rather than ignoring them, will only improve the ecosystem for all the players in this market.

Source: TokenMarket News
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ICO admits its own website fails to comply with GDPR

ICO admits its own website fails to comply with GDPR

You couldn’t make this sh*t up

IN A WILD TWIST OF IRONY, the Information Commissioner’s Office (ICO) has admitted that its own website isn’t GDPR-complaint. 

The ICO –  you know, the regulator that enforces GDPR in the UK – has been forced to own up to the fact that its current consent notice relating to the use of cookies on mobile devices failed “to meet the required GDPR standard”.

This confession came after Adam Rose, a lawyer at Mishcon de Reya, discovered the privacy screw-up, which saw the ICO relying on  “implied consent” to automatically place cookies on mobile devices when visitors accessed its website.

Rose argued that this is was a breach of Article 6 of the Privacy and Electronic Communications Regulations (PECR) 2003, the Telegraph reports. PECR – which sits alongside GDPR – prohibits the storage of, or access to, information held on a user’s device unless explicit consent is given.

This is even explained clearly on the ICO’s website, where the watchdog warns companies that: “You must tell people if you set cookies, and clearly explain what the cookies do and why. You must also get the user’s consent. Consent must be actively and clearly given.”

Rose argued that because of the ICO’s use of implied consent, which saw cookies used automatically, users were unable to reject their use.

In an email sent to Rose, an ICO bod fessed: “I acknowledge that the current cookies consent notice on our website doesn’t meet the required GDPR standard.”

“We are currently in the process of updating this to align our use of cookies to the GDPR standard of consent and we will be making amendments to this information during the week commencing 24 June.”

In response to the tweet, in which Rose touted the ICO’s admission as “remarkable”, Simon Jones, the founder and MD of Studio 24, quipped: “Given the amount of effort some people go to to comply, it’s deeply ironic that [the ICO] are lacking in their cookie policy. I see they use a tool for this. Are there any tools that actually meet current best practices?”

In addition to GDPR-ifying its own website, the ICO said it also be publishing “updated, detailed guidance on cookies for organisations soon.” µ

Further reading

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Bitcoin Price: Predictions for 2019

Bitcoin price predictions are all too common. There are authorities whose predictions will be taken very seriously while some taken more lightly. However, the volatile nature of cryptocurrency, bitcoin has had a good year. Increasing value since February at $3500 to $8200 in May. With a year like this, bitcoin holders naturally became enthusiastic about the year, then came the June drop due to the sell-off. Such a turn resulted in an attention to prices prediction. Although bitcoin price prediction may not always be 100% accurate because there is no systematic formula for it; paying attention to n what enthusiasts are saying can help you anticipate some fluctuations.

Bitcoin price predictions are necessary because it can inform investment decisions of bitcoin holders (when to invest, what to invest in, etc.) and after the June swing, the need for this is well underway. We need to look at several predictions and try to connect the dots rather than just depend on one price prediction. Below are some of the top bitcoin price predictions for 2019.

Bitcoin price prediction

  1. John McAfee: John McAfee’s bitcoin prediction is definitely the most exciting prediction being made about 2019 bitcoin price, saying that bitcoin price will get to $1 million by the end of 2020. This is exciting not only because of the scale of the prediction but also to the attitude he attached to it, saying he would perform a ridiculous act on live television. $1 million bitcoin price is on the high side and John seems so sure of his prediction that every crypto enthusiast out there is keeping up, looking towards what will happen. With the dollar value of bitcoin at the moment still less than $10000, there is definitely a long way to go before it hits 1 million. However, considering the volatile nature of Bitcoin, you can’t completely rule out the possibility.

  2. Jesse Lund: Before any of bitcoin’s increase, Jesse Lund predicted in February that bitcoin’s price will increase up to $5000 at the end of 2019 and then eventually get up to 1 million in 2020. This makes John McAfee’s prediction even more interesting because it has the same foresight for the end of 2020, hence, makes the prediction even more believable. With a closer look at Jesse Lund’s prediction, we can see that Bitcoin price has already exceeded the amount he predicted and almost doubled it in May. Hence most crypto enthusiasts, even those that rather play it safe believe in Jesse Lund’s prediction, even making investment decisions in that light.

  3. Zhu Fa, Poolin co-founder: Zhu Fa also has his prediction about bitcoin. This prediction is worth listening to because he owns the Poolin mining pool which accounts for 10% of Bitcoins being mined. It is from this experience that Zhu Fa’s prediction is informed, he believes that bitcoin will increase in value getting up to quarter of a million. With three people predicting about a million in bitcoin’s value, it is viable to want to believe in that number.

  4. Sony Singh: Sony Singh also his prediction for bitcoin’s value at the end of 2019. After being interviewed by Emily Chang, Sony admitted that he expects bitcoin price to increase to a large extent from the $3500 value it began with in February. Sony explained that by November, Bitcoin price should be well between $15000 and $20000 backing this up with the possibility of crypto related ETF start-up. As the chief commercial officer at Bitpay and with his reason being backed up by possible future advancement in the industry, Sony’s prediction enters as one of the top predictions for bitcoin price in 2019. Especially seeing as other crypto-related industries in the past have led to an increase in the price of bitcoin.

  5. A survey of Bitwise Financial advisers: Financial advisers at Bitwise came together to give their individual 4 years predictions for the price of Bitcoin, and then a mean of the predicted values was taken. The result showed optimism towards the expected value of Bitcoin. They came up with $17571 price for bitcoin in the next 5 years (2023). This value was informed by them playing a safe and realistic approach to their predictions rather than an outright optimism towards what they expect. The collective prediction of these financial advisers although safe, is a value that is easy to work with considering their knowledge and experience at Bitwise.

  6. Bobby Lee: Bobby Lee predicted an up and down case in the future value of Bitcoin, expecting it to reach $333000 by 2020 but then drop further to $41000 in 2023. However, in addition he views the major turning point for bitcoin to be at $60000 after which there will be a very steep increase before the future decline. Bobby Lee roots his prediction in his knowledge of financial history and expects that in a case where history is repeated, these are what is to be expected in the bitcoin price market.

  7. Coinswitch: After a review of different long term and short-term Bitcoin predictions, an article published by Coinswitch shows a prediction for the price of bitcoin at the end of 2019. Coinswitch maintains an optimistic approach towards the future of Bitcoin, considering the pros of Coinswitch and BTC future launched by NASDAQ. Their price prediction has Bitcoin price getting up to $23499 at the end of 2019 with even more increase predicted for 2020.

At the end of all the predictions, one notable fact is that everyone expects bitcoin to increase value at the end of the year 2019, with different value predictions, the lowest being the $5000 prediction by Jesse Lund. Although with bitcoin prices, there is always a looming possibility that predictions can go wrong and one or two person’s may be wrong, sometimes the price goes up beyond fore-seen predictions. Hence, it is important to pay attention to bitcoin price prediction from informed individuals who are not only bitcoin holders but are active in the technological phase of Bitcoin. A summary is that 2019 will be a good year for Bitcoin prices with a possible increase from the current $8700 at the end of the year.

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Crypto Expert Stephen McKeon Comments on Kik’s ICO Battle with the Security and Exchange Commission

It has been widely known that Kik was engaged in a cage match with the Securities and Exchange Commission (SEC) ever since Kik went public regarding a Wells Notice submitted by the SEC. A Wells Notice informs an entity they may be the target of an SEC enforcement action.

In late 2017, Kik sold “Kin” tokens to both accredited and non-accredited investors. The first round was completed as a SAFT to accredited investors and once Kik could claim the network was viable, Kin sold additional tokens to anyone.

In total, Kik raised a huge amount of money, approximately $100 million. The Kin ICO remains one of the largest digital asset offerings ever.

Kik responded to the Wells Notice defending its position in an extended outline of why the ICO should not be considered an unregistered security offering.

While support across the crypto industry was initially strong, questions started to percolate when a video surfaced showing a Kik representative pitching the ICO as an investment.

Earlier this month when the SEC enforcement division revealed its legal complaint it became clear the SEC Enforcement Division was prepared to fight. The language was critical of Kik’s operations calling the ICO a “Hail Mary Pass” as the company was portrayed as being in a spiral. Beyond any hyperbole, the fact that money had been raised post-DAO added to the argument that the manner of sale indicated a sale of an investment. This caused some industry insiders to question whether, or not, Kik was the right fight to back.

A DefendCrypto website, set up by Kik to raise a defense fund for what could be a protracted legal battle, saw several prominent defections once the SEC publicly posted the details of its case against Kik.

Crowdfund Insider recently reached out to Stephen McKeon, a Professor of Finance at the University of Oregon. McKeon is an academic expert in cryptocurrency, Bitcoin, and corporate finance, including venture capital, private equity, and entrepreneurial finance. McKeon is also the Chief Strategy Advisor at the Security Token Academy.

McKeon shared his opinion on the Kik case and pending legal clash – which may end up defining the industry going forward.

Our discussion is shared below.


The SEC complaint against Kik was pretty damning – yes?

Stephen McKeon: The fact that the SEC feels confident enough in its interpretation of the facts to bring it to court is a strong signal that they think they can win.

They conclude that “investors’ purchases of Kin were an investment of money, in a common enterprise, with an expectation of profits for both Kik and the offerees, derived primarily from the future efforts of Kik and others to build the Kin Ecosystem and drive demand for Kin.” In other words, the SEC asserts that the Kin sale satisfied all of the prongs of the Howey test and as such was an offer and sale of securities.

In the Wells Response, how did Kik argue against the claims asserted by the SEC?

Stephen McKeon: Kik focuses on two prongs of the Howey test – they assert that Kin purchasers were not led to expect profits, and claim that no common enterprise was involved in the arrangement. 

The second piece is the most interesting – Kik argues that “simply owning a common asset whose value rises and falls depending on market forces does not give rise to a “common enterprise” for purposes of Howey.”

Is the fact it was documented that Kik pitched the Kin ICO as an investment a fatal blow?

Stephen McKeon: Not necessarily – all prongs of the Howey test must be satisfied in order to deem this a securities offering. The legal interpretation of “common enterprise” seems to be Kik’s strongest chance for a successful defense in this case.

Stephen McKeon: Many initial supporters were – and continue to be – frustrated with the lack of regulatory clarity on crypto assets from the SEC and felt this case represented a step backwards in reversing prior guidance.

The SEC’s formal complaint makes clear they are not walking back prior guidance, turning this from what was perceived as a broader battle for legal clarity to a more narrow argument over the facts of Kin’s particular case – primarily how the Kin sale was marketed to purchasers.

There are many who want greater regulatory clarity from the SEC, but perhaps fewer who feel strongly about Kin’s particular case.

Has the Crypto industry picked the wrong battle?

Stephen McKeon: It is fair to say that the crypto ecosystem is not unanimously in agreement that this is the right battle to fight, but the industry in an interesting chicken-and-egg situation.

We need regulatory clarity to innovate with confidence, but the SEC uses examples in order to provide that clarity.

It’s important that we continue to innovate and engage with regulators early and often.

Whether Kik prevails or not, what are your thoughts on a path to a tradable utility token in the US?

Stephen McKeon: One thing the SEC’s suit makes fairly clear, now that the full complaint in the case against Kik is public, is that this suit does not signal any policy reversal on the SEC’s part.

Hinman’s prior guidance indicating BTC and ETH are not securities due to their sufficient decentralization stands, and could be applied in the future to similar cases/tokens.

Blockstack is doing interesting work with their planned offering of their STAX tokens, launching them as regulated securities.

Other projects (like Algorand) are choosing to launch their tokens outside of the US initially to avoid the jurisdiction entirely.

In both cases, the hope is that eventually, the networks will become sufficiently decentralized that the tokens will no longer be considered securities in the US.

As a final note, there will continue to be tokens, particularly those that represent ownership claims on traditional assets, that will be securities throughout their lifecycle.

Editors Note: Matt Lucas, an Analyst at Collaborative Fund, assisted McKeon with the responses. He is a graduate from Princeton University in 2018 with a degree in Economics. 

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