Are Bad Actors Checks Required For Security Token Offerings (STOs)?

Bad Actor checks are mandatory for anyone doing a Security Token Offering (STO) on Regulations D506c, Regulation S or Regulation A+.┬áThis is an important anti-fraud and due diligence requirement to ensure disqualified persons do not raise funds. Token offerings have attracted numerous scammers in the past. Before various countries started to crack down on initial coin offerings (ICOs), it was pretty easy for some con artists to put together a fake white paper and a roadmap, launch a token and split with the money. The U.S. Congress is now in the primary stage of a series of legislative fixes directed …

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Do You Need An Escrow for Your Security Token Offering (STO)?

In this article, I’ll go over the importance of an escrow for your securities token offering (STO). I’ll also cover the requirements of Money Services Business (MSB) and Bank Secrecy Act (BSA) as it relates to an STO. Financial Crimes Enforcement Network (FinCEN) made public a letter on March 6, 2018, that seems to have been overlooked by many entrepreneurs who intend to launch STOs in the US. Everyone by now understands that they must comply with Regulation D506c, Regulation S, Regulation A+ or Regulation CF exemption to launch their security token. But FinCEN laid out a reminder for every …

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