Tokens

SEC’s TurnKey Jet No-Action Letter Indicates Baseline for Utility Tokens

On Apr. 3, 2019, the SEC Division of Corporation Finance (“Division”) issued a no-action letter  to TurnKey Jet, Inc. (“TKJ”) in response to TKJ’s incoming letter dated Apr. 2, 2019. At the same time, the Division released a paper entitled “Framework for ‘Investment Contract’ Analysis of Digital Assets” (see accompanying…

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The SEC Releases New “Framework” to Analyze Digital Assets under Securities Laws

On April 3, 2019, the Securities and Exchange Commission (“SEC”) released the “Framework for ‘Investment Contract’ Analysis of Digital Assets” (the “Framework”). The Framework—published by the SEC’s Strategic Hub for Innovation and Financial Technology (“FinHub”) —is the most comprehensive guidance the SEC has provided to date with respect to a…

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