Can an ICO do token Airdrops to U.S residents?

BrightCOIN’s legal counsel wrote a really good article on the matter. The high-level takeaway is- DO NOT do Airdrops to American residents. Anil Advani from Inventus Law said “Founders, therefore, have to be careful in structuring their Airdrop or free stock giveaway offerings because those will very likely be: (a) treated as issuance of securities; and (b) subject to the Securities Act, and subject to registration or a specific exemption under the Act.” Full article here 

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