Overview
The SEC announced yesterday that “offers and sales of digital assets by ‘virtual’ organizations are subject to the requirements of the federal securities laws.” Although not coming as a surprise, the SEC’s announcement affirms that companies seeking to involve US investors in an initial coin offering (ICO) must register offers and sales with the SEC or else qualify for an exemption.
The SEC chose the token offering by the Distributed Autonomous Organization (DAO) in April-May 2016 as the focus of the study. The DAO was built on top of the Ethereum blockchain by the German unincorporated organization Slock.it, and the success of its token offering ushered in the current wave of ICO activity. Although questions surrounded the DAO offering in terms of its prospective treatment under US securities laws, the DAO made headlines when it suffered an exploitation that led to the loss of $50 million in Ether. Although the SEC found that DAO “may have violated federal securities laws,” it decided against pursuing an enforcement action, choosing instead to use DAO as a demonstrative for future ICOs (“to advise those who would use a Decentralized Autonomous Organization … or other distributed ledger or blockchain-enabled means for capital raising, to take appropriate steps to ensure compliance with the US federal securities laws”).
To reach its conclusion that DAO fell under US securities laws, the SEC applied a traditional four step analysis derived from U.S. case law (most notably SEC v. W.J. Howey Co., 328 U.S. 293, 301 (1946)). Under that analysis, the SEC held that:
- Foundational principles of the securities laws apply to virtual organizations or capital raising entities making use of distributed ledger technology
- Investors in The DAO invested money
- These investors had a reasonable expectation of profits
- The profits were to be derived from the managerial efforts of others