The US Securities and Exchange Commission (SEC) has filed a number of enforcement actions recently challenging the issuance and sale of cryptocurrencies, including challenging the disclosures accompanying the sale of cryptocurrencies. The SEC takes the position that the tokens or other measures of value issued in initial coin offerings often are securities, and thus if sold in the United States are subject to US Securities laws. This week the SEC ratcheted up the pressure, issuing numerous subpoenas to companies and funds in an industry "sweep," demanding voluminous documents and information, including sales and pre-sales information. If you are the recipient of one of these subpoenas, consider contacting your counsel to respond. Violations of securities laws can result in both civil and criminal liability, and the failure to respond appropriately to an SEC subpoena carries its own set of sanctions.
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