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      "body": "Congratulations @mazilinig! You received a personal award!\n\n<table><tr><td>https://steemitimages.com/70x70/http://steemitboard.com/@mazilinig/birthday2.png</td><td>Happy Birthday! - You are on the Steem blockchain for 2 years!</td></tr></table>\n\n<sub>_You can view [your badges on your Steem Board](https://steemitboard.com/@mazilinig) and compare to others on the [Steem Ranking](https://steemitboard.com/ranking/index.php?name=mazilinig)_</sub>\n\n\n**Do not miss the last post from @steemitboard:**\n<table><tr><td><a href=\"https://steemit.com/steemfest/@steemitboard/steemfest-meet-the-stemians-contest-the-mysterious-rule-revealed\"><img src=\"https://steemitimages.com/64x128/https://cdn.steemitimages.com/DQmasWw4jQHwxng82DKxY6Q6tVg9mWcto4xcDURs8knFgCa/image.png\"></a></td><td><a href=\"https://steemit.com/steemfest/@steemitboard/steemfest-meet-the-stemians-contest-the-mysterious-rule-revealed\">SteemFest Meet The Stemians Contest - The mysterious rule revealed</a></td></tr></table>\n\n###### [Vote for @Steemitboard as a witness](https://v2.steemconnect.com/sign/account-witness-vote?witness=steemitboard&approve=1) to get one more award and increased upvotes!",
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      "body": "![1-01.jpg](https://steemitimages.com/DQmeynTES4Ah4BjRx8wZKaSZF6wBe6zLHjKVfWexuiSKg6G/1-01.jpg)\n<p>The establishment of the High Technologies Park (HTP) in 2005 has played an important role in &nbsp;stimulating growth of the IT sector in Belarus. The HTP regime had laid the groundwork for successful development of the park and attracted foreign investments.</p>\n<p>Such projects as World of Tanks, MSQRD, Viber, Maps.me, Prisma, Apalon Apps and others started at HTP. &nbsp;Belarus has set a course for creating a prototype of the Silicon Valley in the republic and has been following that course persistently.</p>\n<p>Unlike the majority of Europe and Asia-based Silicon Valleys, Belarus' HTP is a virtual park: resident companies are located throughout Belarus in Minsk, Mogilev, Gomel, Grodno, etc. The HTP applies the exterritorial principle of registration of resident companies. It means that the legal framework of the HTP extends to the entire territory of the Republic of Belarus. Such approach allows more efficient utilization of capabilities of resident companies and stimulates the nation&amp;rsquo;s potential for growth in the areas of education, science, research and professional services.</p>\n<p>At the end of 2017, HTP had close to 200 resident companies, half of which were foreign companies or joint ventures with foreign shareholders. The HTP residents have customers in over 60 countries worldwide, with over 90 percent of sales attributed to foreign consumers:mainly from Europe (49%), US (43%), Russia and CIS (5%).</p>\n<p>On 21 December 2017, Belarus President Alexander Lukashenko signed a Decree No. 8 \"On the Development of Digital Economy,\" also known as HTP Decree 2.0 (the Decree). The primary objective of the Decree was to legitimize the key concepts of the crypto industry and to set the rules of the game in the cyber economy environment within the HTP.</p>\n<p>The development of the Decree was initiated in spring 2017 with the order of Alexander Lukashenko. Over 100 representatives of the IT industry and the expert community were involved in the drafting and negotiation of the draft decree. The process was coordinated by Vsevolod Yanchevsky, director of HTP. The first draft was published in July 2017, and at the beginning of December the draft decree was approved by the competent authorities without any critical remarks and submitted to the president. The Decree will come into force in March 2018.</p>\n<p>The Decree includes the following notable features:</p>\n<ul>\n<li><strong>Extension of the special legal framework</strong>: A special legal framework for resident companies (that was introduced back in 2005 when the HTP was established) has been extended until end of 2048 (i.e. by 28 years from the expected termination in 2020) - companies engaged in development of innovative technologies seem to be able to enjoy the most favorable regime</li>\n<li><strong>Extension of eligible types of activities</strong>: Annex 3 to the Decree contains an extended list of business activities allowing a company to become an HBT resident. The list comprises thirty-eight types of business operations including development of biotechnologies, medical, aviation and space technologies, cybersport, and blockchain. The list is not exhaustive and other types of businesses might be also admitted by the decision of the HTP supervisory counsel. As far as blockchain is concerned, the list contains such operations as (i) launch of token generation events, including its promotion and other ancillary services; (ii) set-up and operation of cryptocurrency exchanges; (iii) cryptocurrency exchange operations; (iv) mining; (v) other operations involving tokens, including operations that can be treated as professional or exchange operations involving securities, investment fund operations, securitization, and token generation and placement operations</li>\n<li><strong>Introduction of definitions</strong>: Annex 1 to the Decree contains legal definitions of such terms as \"cryptocurrency,\" \"token,\" \"smart contract,\" \"blockchain,\" \"cryptocurrency exchange operator,\" \"cryptoplatform operator,\" \"virtual wallet,\" and \"mining.\"</li>\n<li><strong>Application of securities laws</strong>: according to the Decree, operations involving tokens are not subject to securities and securitization laws and do not require acquisition of professional or exchange operation licenses. It means that the preparation of offering prospectuses shall not be required in case of ICOs</li>\n<li><strong>Liability of token issuers to investors</strong>: the Decree provides for the liability of an issuer \"for satisfaction of a token holder's demands vested in a token holder upon creation and placement of tokens.\" A refusal to satisfy such demands with reference to the non-existence or invalidity of the relevant obligations is prohibited, which, to a certain extent, protects the investors' interests</li>\n<li><strong>Waiver of regulatory requirements</strong>: mining, the activities of a crypto-platform operator or a cryptocurrency exchange operator, and other operations involving tokens are not regarded to be banking activities and do not require either registration, a license, or anything else other than an obligation to guarantee the availability of funds for bank accounts opened at banks within the Republic of Belarus: 1 mln Belarusian Roubles in the case of crypto-platforms and 200k Belarusian Roubles in the case of cryptocurrency exchange offices</li>\n<li><strong>Tax privileges</strong>: until 1 January 2023, HTP residents are exempt from VAT and corporate profit tax (or individual income tax) in relation to turnover and profits (proceeds) from mining, creation, acquisition, and disposal of tokens, while individuals are exempt from individual income tax from mining, acquisition (including as a gift), and disposal of tokens in exchange for Belarusian Roubles, foreign currency, e-money and/or other tokens. &nbsp;For accounting purposes, tokens created (or mined) or otherwise acquired are regarded as assets</li>\n<li><strong>Cutting of red-tape for HTP residents</strong>: (i) the requirements to obtain regulatory approvals to open accounts with non-resident banks are waived; (ii) the process of settlements involving e-money is simplified; (iii) FX operations relating to capital flow are allowed subject to the notification of the relevant authorities; (iv) no special permits or licenses are required &nbsp;in connection with the technical and/or cryptographic protection of data, whether it be by individuals &amp;ndash; in connection with the storing, acquisition, or disposal of tokens &amp;ndash; or by legal entities &amp;ndash; in connection with mining, storing, acquisition, disposal, and other transactions (operations) involving tokens, etc.</li>\n<li><strong>Introduction of English law concepts</strong>: convertible loan agreement; option agreements; indemnities, non-compete (non-solicitation) agreements with employees (subject to payment of average salary to employees for a period during which they may not join competing entities), investment partnership agreements, irrevocable POAs, etc.; foreign individuals employed by the HTP are also provided with certain visa and migration privileges.</li>\n</ul>\n<p>As a result, Belarus has established something like a sandbox-in-sandbox with milder and more comprehensive and straightforward regulatory framework in comparison with other jurisdictions that introduced regulatory sandboxes earlier (United Kingdom, Abu Dhabi, Singapore, etc.). For example, in Singapore the sandbox projects mostly (a) have just 6 months to achieve the set goals, on the expiry of which the regulator (MAS) would determine, whether the project can operate outside of the sandbox or should be discontinued, (b) are subject to certain minimum capital requirements that would guarantee the protection of the client&amp;rsquo;s interests in case of the project&amp;rsquo;s failure, and (c) are provided with tax benefits only on a case by case basis. Similar regulations apply to the sandbox projects in UK. &nbsp;</p>\n<p>However, the benefits and impact of the Belarusian Decree might be overestimated by the media. For instance:</p>\n<ul>\n<li>At this stage, no fundamental changes have been made to the applicable laws to test-drive the novelties. &nbsp;So far, it looks like \"let's allow everything and see how things turn out\". &nbsp;If anything goes wrong, the limitations may be quickly introduced by an identical decree</li>\n<li>Tax privileges for HTP residents create a kind of \"offshore jurisdiction\". However, issuing a degree is hardly enough to establish an attractive tax haven jurisdiction for international businesses. &nbsp;This might be particularly challenging with the Belarus reputation as \"the last dictatorship in Europe\" (quoting the former UK ambassador to Belarus Brian Bennett and various media reports), high criminal criminal charges for economic offences and the police nature of the state in general</li>\n<li>It is not likely that mining will become popular in Belarus since electric power is expensive enough there</li>\n<li>The Decree introduces English law concepts which is instrumental in the structuring of deals and business in general, however, does not remove the risks related to enforceability of respective arrangements (due to the lack of practice or consistency in application of such concepts by courts and government authorities). The Decree also does not identify or establish a specialised court which would consider claims from investor if he believes that his rights have been infringed (for example, in the ICO process)</li>\n<li>The Decree has a rather declarative nature. Its force is based on the course set by the President, but it does not provide firm and institutionalised instruments of implementation and enforcement. Of course, it is more than good enough in Belarus and would definitely have an effect, although primarily for internal use.</li>\n</ul>\n<p>There will definitely be an emergence of token exchanges, crypto-platforms and other blockchain solutions in this \"heavenly\" sandbox. Moreover, foreign companies will probably have some interest in some infrastructure projects. However, in our opinion it is unlikely that this will lead to a major influx of foreign investments in view of the existing political climate in Belarus. The biggest inflow can probably be expected from investors from CIS countries that might not have access to a better alternative.</p>\n<p>Nonetheless, for the CIS countries, the Decree is a good demonstration of a starting point in the area of the regulation of innovative technologies. Hopefully, these developments in Belarus will also give additional support to the initiatives of creation of the regulatory sandboxes in Russia that are becoming increasingly popular.</p>",
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      "body": "Thanks mate! Much appreciated.",
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      "author": "mazilinig",
      "body": "![iStock-494899266.jpg](https://steemitimages.com/DQmass1cuVaRGNErTLFV6u8yAd5BPs9FoxqgwjU5SGehA7a/iStock-494899266.jpg)\n<p>Following upon my article on EOS offering (<a href=\"https://steemit.com/cryptocurrency/@mazilinig/what-are-you-buying-when-investing-in-icos-lawyer-s-perspective-on-eos-token-offering\">https://steemit.com/cryptocurrency/@mazilinig/what-are-you-buying-when-investing-in-icos-lawyer-s-perspective-on-eos-token-offering</a>) below is an attempt to summarise current approaches to ICO transaction structuring. It is too early to say that there is some sort of market practice in this industry. In fact, it is the opposite. In an environment with very little to none regulation legal practitioners are still trying to figure out their positions.</p>\n<p><strong>Jurisdiction of token issuer incorporation</strong></p>\n<ul>\n<li>Choice of jurisdiction of incorporation of token issuers is primarily driven by tax and attitude towards cryptocurrency capital raisings</li>\n<li>No safe haven jurisdiction for conducting ICO exists as of now. No country has yet implemented a detailed set of guidance re dealings with crypto assets (including capital raisings)</li>\n<li>Regulatory attempts so far mostly related to alerts on relevance of AML compliance to operations with cryptocurrencies and necessity to respect financial industry regulations (currency, commodity and security) with more concerns voiced than answers given</li>\n<li>United States, Japan, Isle of Man, Singapore, Gibraltar and Hong Kong are in neutral to permissive camps with their financial regulators attempting to bring ICOs under the established regimes for financial transactions and securities offerings</li>\n<li>China and South Korea are primary examples of a restrictive camp &nbsp;</li>\n<li>Most commonly used jurisdictions are zero tax zones as Cayman (EOS, Tierion, BAT), BVI (Storj), Gibraltar (Gnosis, Coindash, Brickblock) which allow for zero tax leakage of proceeds and for simplified accounting of crypto tokens &nbsp;</li>\n<li>Delaware incorporated companies are also commonly used in high profile offerings (eg. Filcoin, Blockstack). ICO proceeds from these offerings are likely exempt from profit tax as most Delaware offerings are done under SAFTs which are considered securities</li>\n<li>Switzerland became a posh and well advertised jurisdiction at the start of ICO mania due to FINMA relaxed approach, availability of such legal form as the foundation, possibility to negotiate tax exemptions and early benchmark projects such as Etherium and DAO incorporating there. FINMA approach to ICOs since then has changed to cautious and investigative and no regulations have so far been implemented despite press announcements. Such notorious projects as Bancor, Tezos and Status have also chosen to implement a Swiss foundation structure in their capital raisings &nbsp;</li>\n</ul>\n<p><strong>Types of corporate structures</strong></p>\n<ul>\n<li><em>Corporation (two-tier economic) structure</em></li>\n<ul>\n<li>Structure is under control of equity holders of a corporation which develops the project</li>\n<li>Corporation issues tokens to finance the project</li>\n<li>All intellectual property sits on a corporation balance sheet</li>\n<li>Token holders are participating in the token economics within a framework of the project, hence are dependent on the will of equity holders to continue with the project in a shape initially presented</li>\n<li>Equity holders are theoretically capitalising on the success of the project through their equity holdings in a corporation</li>\n<li>Filecoin and Blockstack and, particularly, EOS are examples of such structure but equity holders risk is mitigated by the fact that software once open sourced and a decentralised platform once launched should lead to equity holders losing their leverage on token holders as the platform would detach from the team that developed it</li>\n</ul>\n</ul>\n<ul>\n<li><em>Foundation (non-profit organisation) having contractual relations with operational company</em></li>\n<ul>\n<li>Tokens are issued by the foundation</li>\n<li>Foundation is independent of the project development team</li>\n<li>Foundation employees a board of directors that manages and supervises use of proceeds and token distribution</li>\n<li>Project development team is employed by the operational entity</li>\n<li>Operational entity commits to using tokens issued by the foundation in a product that it develops or undertakes to open source the software or transfer the product to foundation once it is developed</li>\n<li>Structure allows project development team to keep control of its operations while the project is developed and cash out (eg. Tezos) at the time of project transfer to the foundation. At the same time it provides more comfort to token holders that at least the use of funds and token distribution are supervised by the board that is independent of the development team &nbsp;</li>\n<li>Examples of such structures are Tezos and Bancor. KIK and MobileGo also declared that they would implement some sort of foundation type structure.</li>\n</ul>\n</ul>\n<ul>\n<li><em>Foundation acting on its own</em></li>\n<ul>\n<li>Foundation conducts the token offering and uses its proceeds to hire team of developers to develop a project</li>\n<li>Once project is developed and launched foundation keeps promoting it</li>\n<li>Foundation&amp;rsquo;s activity is charitable as it gains no profit out of project</li>\n<li>Etherium is the best example of such structure</li>\n</ul>\n</ul>\n<p><strong>Legal form of token issuer incorporation</strong></p>\n<ul>\n<li><em>Private corporation</em>\n<ul>\n<li>Filecoin and Blockstack (Delaware)</li>\n<li>EOS, Tierion and BAT (Cayman)</li>\n<li>Storj (BVI)</li>\n<li>Gnosis, Coindash and Brickblock (Gibraltar)</li>\n<li>TenX (Sinapore) &nbsp;</li>\n</ul>\n</li>\n<ul>\n<li>The most utilised form of legal entity in ICOs</li>\n<li>Examples include</li>\n<li>Founders maintain control over ICO proceeds and token distribution</li>\n<li>Risk of founders circumventing the ICO use of proceeds and token distribution representations persists</li>\n<li>Operations could vest in the token issuing entity</li>\n<li>Corporate and capital gain tax may apply to ICO proceeds and tokens kept on the balance sheet unless registered in a zero tax offshore jurisdiction</li>\n<li>Having an issuer entity incorporated in offshore jurisdiction may result in much longer KYC clearances with banks and crypto exchanges&nbsp;&nbsp;</li>\n</ul>\n</ul>\n<ul>\n<li><em>Foundations / Non-profit organisations</em>\n<ul>\n<li>Etherium, Tezos and Bancor (Switzerland)</li>\n<li>KIK (Canada, though not officially disclosed in the offer documents)</li>\n<li>MobileGo (place of incorporation is not disclosed)</li>\n</ul>\n</li>\n<ul>\n<li>Used in a number of high profile ICOs</li>\n<li>Most notable examples include</li>\n<li>Although Switzerland is the most widely marketed jurisdiction any other civil law jurisdiction could theoretically be used (eg. Dutch stichting)</li>\n<li>Founders lose control over ICO proceeds and token distribution</li>\n<li>Eliminates the risk of founders circumventing the ICO use of proceeds and token distribution representations</li>\n<li>Usually tax exempt unless involved in business activity (Zug requires tax exemption to be negotiated with tax authorities)</li>\n</ul>\n</ul>\n<p><strong>Use of proceeds</strong></p>\n<ul>\n<li>Varies from declarations that all proceeds will be spent at the sole discretion of the token issuer (eg. EOS) to commitments to allocate all proceeds to fund operations and develop the project (eg. Filecoin)</li>\n</ul>\n<p><strong>Governance over use of proceeds and token distribution</strong></p>\n<ul>\n<li>Governance procedure are rarely disclosed in detail in white papers and offer documents</li>\n<li>Most projects have not implemented any governance procedures except for commitments in their offer documents with respect to use of proceeds</li>\n<li>Some projects employed (eg. Tezos) or claim that they will employ (eg. KIK and MobileGo) foundation structures with independent boards to take management of the use of proceeds and supervise token distributions.</li>\n</ul>\n<p><strong>Tokens offer structure</strong></p>\n<ul>\n<li>Depends on a set of jurisdictions where tokens are offered to</li>\n<li>US is the most feared because of US persons tendency to litigate and SEC enforcement reputation</li>\n<li>From the perspective of sales into US it should be assumed that tokens are securities unless the platform is launched and purchasers could utilise tokens at the time of the offering</li>\n<li>Some high profile issuers (eg. EOS) chose to exclude US persons from their token distribution to mitigate the risk of US litigation</li>\n<li>Those who wish to offer into US are invited to use SAFT offering structure whereby options to purchase tokens are offered to qualified investors instead of tokens. SAFT structure nevertheless leaves the question on whether tokens themselves are securities unanswered, hence pushing issuers to keep close ties with their lawyers all the way through project development stage to have them finally opine on when the risk of requalification is mitigated. Examples of SAFT offering are Filecoin and Blackstock. Others who conducted token sales into US with no MVP in place at the time of the offering face a risk of SEC prosecution &nbsp;</li>\n<li>Other jurisdictions such as Singapore, France, Hong Kong, Switzerland also voiced concerns and warnings regarding potential applicability of their securities laws. However, in the lack of clear guidance from regulators in those jurisdictions and perhaps a more formalistic approach to defining what a security is they are being considered of less risk &nbsp;</li>\n</ul>\n<p><strong>KYC / AML</strong></p>\n<ul>\n<li>Approaches to KYC are polar varying from no practical KYC steps taken at all (eg. EOS) to strict KYC requirements of submission of copies of identity documentation and proof of professional investor status (eg. KIK, Filecoin, Brickblock)</li>\n<li>Projects that employed KYC compliance usually require the verification of ID (passport, driving licence, ID card), biometric facial verification by means of comparison of selfie vs ID picture, verification of supporting documents (such as bank statements and/or utility bills)</li>\n</ul>\n<p><strong>Disclosure</strong></p>\n<ul>\n<li>It is not market practice to provide for clear disclosure of corporate structure, names and places of incorporation of various group entities</li>\n</ul>\n<p><strong>Development team liability</strong></p>\n<ul>\n<li>In most examples, teams seek full release of liability and reserve the right to terminate the project</li>\n<li>General approach is that no funds are returned in case of failure or termination of the project with few exception (Filecoin documentation provides for return of all investments in possession of Protocol Labs in the event the Filecoin project is abandoned)</li>\n<li>No obligations to report on team being on track with the project milestones are usually contained in the offer documents</li>\n</ul>\n<p><strong>Documentation</strong></p>\n<ul>\n<li>WP is usually a technical document that describes the project. Some WPs describe the offer structure however usually this is done in such documents as terms of sale, token sale agreement or SAFT</li>\n<li>In addition to WP some issuers have been preparing marketing brochures</li>\n<li>FAQs sometime provide additional disclosure that is not contained in WP and offer documents</li>\n<li>Legal documents used (depending on the offer structure) are terms of sale, &nbsp;token sale agreements, SAFTs</li>\n<li>Privacy Policy and term of use are also prepared for the website from which the ICO is launched</li>\n<li>SAFT structures also use additional disclosure pack consisting of private placement memo and a number of other documents</li>\n</ul>\n<p>&nbsp;</p>",
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      "body": "Great summary. thanks!",
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      "author": "mazilinig",
      "body": "# <p><strong>What are you buying when investing in ICOs? Lawyer's perspective on EOS token offering.</strong></p>\n![iStock-868565168.jpg](https://steemitimages.com/DQmWxp9KgKNCrbBp9QwLGhPMHzxRUdrKQRtfEJWZ8KYytFv/iStock-868565168.jpg)\n<p>I am a corporate and securities lawyer by training and have been helping companies go public and raise capital in the financial markets for the past ten years. This was always a painful and time consuming exercise that involved various advisors verifying each and every statement in offering documents. Crowdfunding of startups has never been part of this big play but ICOs carried it to an apogee. The amount of capital raised through recent ICOs is remarkable, with transaction values reaching levels typical to venture capital and securities markets. At the same time, issuers give very few undertakings in exchange of funds raised.</p>\n<p>If you go to a venture capitalist, you would have a hard time defending the potential and budget for your project. If successful, funding will most likely come in tranches tied to your project milestones. In the ICO world, you raise your capital up-front by giving few to no explanations as to why you need a particular amount and how you are going to spend it.</p>\n<p>Much has been said on whether ICOs fall under securities law disclosure regimes, so I would not be discussing this in this post. Most people now seem to have agreed that you should assume they do, particularly if you wish to sell in the US.</p>\n<p>This article examines how ICOs are structured from a legal undertakings perspective. I decided to start the analysis with EOS.</p>\n<p>EOS is an interesting example due to its unique offering structure. EOS ICO is a protracted process strained for almost a year with \"transaction closings\" occurring every day. This is something you would never see in a conventional venture capital and securities transaction. What makes things even more tempting is a moving legal environment around ICOs. With legal positions being formulated and argued by lawyers and regulators by the time block.one completes its EOS offering they may find themselves in a different regulatory world than the one they have been in when the deal was launched. Nonetheless, they do not seem to be afraid.</p>\n<p>There are obviously other ICOs where issuers take different approaches on how they structure their offerings. Hopefully, I will cover those in my next posts.</p>\n<p>As a lawyer, I should make some disclaimers. I have no intention to cast a shadow on block.one team and EOS offering. In fact, I believe they have made all the risks associated with investing into EOS clear to potential purchasers. Also, this is not legal advice, but my personal opinion of the EOS offer structure.</p>\n<p><strong>Key features</strong></p>\n<ul>\n<li>The EOS project was launched by block.one's team of developers.</li>\n<li>block.one's corporate structure is not disclosed and is unclear. Places of incorporation and the names of block.one's operational legal entity and token issuing entity are not disclosed. According to the press and EOS FAQ, the team is primarily located in Hong Kong, while token issuer entity is incorporated in the Cayman Islands.</li>\n<li>ICO was launched on the Ethereum blockchain under the EOS Distribution Smart Contract and ERC-20 EOS Token Smart Contract.</li>\n<li>The token sale price is not fixed. It is determined for each distribution round separately and depends on the amount of ETH contributed to block.one during such round.</li>\n<li>ETH is the only currency accepted in the offering.</li>\n<li>Tokens offered at ICO are EOS Tokens, which are not EOS Platform tokens. EOS Platform tokens do not exist and are expected to be issued at the EOS Platform launch.</li>\n<li>ICO launched on 26 June 2017 and is still ongoing, with the end date set as 1 June 2018.</li>\n<li>As of November 2017, EOS raised circa USD 300 mln (with circa USD 185 mln raised during the initial five-day sale round at the end of June 2017).</li>\n<li>There is no cap on the amount of money to be raised in the ICO. The market expects block.one to accumulate around USD 1 bln by the end of the offering.</li>\n<li>Token supply, in the ICO, co-exists with token supply on the secondary market at exchanges. Speculative arbitrage on a difference between ICO daily round price and price on exchanges is possible.</li>\n<li>EOS Tokens offered at ICO provide no rights to use the EOS Platform, block.one provides no assurance that the EOS Platform will ever be developed, or if EOS Tokens will ever be converted into EOS Platform Tokens. block.one indicates that it will not be developing an EOS Platform. If such platform is ever developed, it would be developed by third parties utilising the EOS Software developed by block.one.</li>\n<li>EOS Tokens are only liquid during the ICO period, following which, they will be locked on the holders wallets until the EOS Platform is developed and launched.</li>\n</ul>\n<p><strong>Issuer corporate structure</strong></p>\n<ul>\n<li>Undisclosed and unclear.</li>\n<li>Token issuer entity and operational / project entity are not disclosed in the offer documents.</li>\n<li>Press relates block.one team to Cayman Islands and Hong Kong.</li>\n</ul>\n<p><strong>Token features</strong></p>\n<ul>\n<li>EOS Tokens offered at ICO have no value, utility, or use. There is no representation given as to whether an operator of the EOS Platform (which may be different than block.one) will allow conversion of EOS Tokens into EOS Platform tokens.</li>\n<li>Tokens become liquid following the end of each allocation period provided the purchaser claims them from EOS Distribution Smart Contract and transfers them into its wallet.</li>\n<li>The liquidity period is, however, limited to the period of the ICO. Once ICO completes (starting with 2 June 2018), all tokens will be locked in token holders' wallets until the EOS Platform is launched. The EOS Tokens might then be converted into EOS Platform tokens (provided EOS Platform is adopted as envisaged by EOS Software). Article 2.6 of the Token Sale Agreement states: \"<em>Within 23 hours after the end of the final period on June 1, 2018, at 22:59:59 UTC, all EOS Tokens will become fixed (ie. frozen) and will become non-transferrable on the Ethereum blockchain. At this point the EOS Token distribution will be complete and any person who wishes to launch a public blockchain platform adopting the open source EOS.IO Software (an 'EOS Platform') will be able to generate a file or 'snapshot' showing the fixed balances of the EOS Tokens from the state of the Ethereum blockchain (the 'Snapshot'). As block.one will not configure and/or launch any EOS Platform, block.one will have no control over when, how or whether the EOS.IO Software is adopted or implemented, or how, when or whether a Snapshot will be created or used or whether an EOS Platform is launched. In order for the balance of your EOS Tokens to be included in the Snapshot if a Snapshot is created, you must register your Ethereum address with an EOS public key</em>.\"</li>\n<li>EOS Tokens are now traded on Livecoin, BTER, Tidex, Kraken, Yobit, Binance, HitBTC, Liqui, and Bitfinex. EOS Tokens were first listed by Bitfinex on 26 June, the first day of the ICO. The next exchange to list them on 1 July was Kraken. Kraken lately delisted EOS/USD and EOS/EUR pairs for the reasons that these pairs were not liquid enough to maintain them, thus keeping only EOS/BTC and EOS/ETH pairs. The EOS/USD pair is now traded on Bitfinex, HitBTC, Yobit, and Livecoin.</li>\n</ul>\n<p><strong>The token distribution model</strong></p>\n<ul>\n<li>Allows for a year-long primary token supply:</li>\n<ul>\n<li>10% allocated to block.one under lockup (not being traded or transferred, vesting starts following the launch of the EOS Platform and continues annually in equal portions during a 10-year period starting from the launch of the Platform).</li>\n<li>20% allocated during Period I (26 June 2017 - 1 July 2017)</li>\n<li>70% to be allocated by 1 June 2018, and it is distributed each day over a 341-day period. Each day (namely, a 23-hour period) is a separate distribution period during which two mln tokens are distributed pro rata amongst all purchasers based on the total ETH contributed during a respective day period (i.e., the fewer participants who take part in the round, the more EOS Tokens are received by those who took part in the day round).The purchasers are also allowed to participate in any future round, depositing ETH in advance.</li>\n</ul>\n</ul>\n<p><strong>Management of funds accumulated during ICO and use of proceeds</strong></p>\n<ul>\n<li>There is no corporate governance procedure with respect to the management of funds accumulated during ICO implemented by block.one.</li>\n<li>The token sale agreement and FAQ published on the EOS website expressly provide that \"<em>...proceeds from the sale of the EOS Tokens will be utilized by the Company in its sole discretion</em>\" and will be \"<em>...the revenue of block.one.</em>\"</li>\n<li>FAQ further provides that \"<em>block.one intends to use certain of the proceeds for general administration and operating expenses, as well as to build a blockchain consulting business focusing on helping businesses re-imagine or build their businesses on the blockchain, developing more open source software that may be helpful to the community and building decentralized applications using EOS.IO Software</em>\" and that block.one does not believe that proceeds from the ICO should be donated into any foundation or non-profit organisation as \".<em>..any blockchain that adopts the EOS.IO Software will generate natural inflation in such blockchain tokens at a rate of five percent per year to be distributed to the platform's block producers in connection with their confirmation of transactions on the platform and to the top three smart contracts or proposals that receive the most amount of votes from holders of such tokens. In this case, such a blockchain will not be reliant on any one foundation, organization, or individual for its growth, development, or maintenance.</em>\"</li>\n</ul>\n<p><strong>KYC</strong></p>\n<ul>\n<li>The token sale agreement requires all purchasers be compliant with AML regulations in their home jurisdiction. The agreement also mentions that block.one may, at any time, request any documents it believes are necessary for KYC and AML checks.</li>\n<li>As a matter of fact, no KYC on purchasers is performed by block.one. No identification documents are required to participate in the offering.</li>\n</ul>\n<p><strong>Documentation</strong></p>\n<ul>\n<li>WhitePaper is very technical and does not contain any information on token offering structure. Published on Github.</li>\n<li>Software Roadmap. Technical document. Published on Github.</li>\n<li>Terms of use. Relate to the use of EOS website and provide for general disclaimers and release of EOS from any liability resulting from the use of EOS website. Published on website.</li>\n<li>Privacy policy. Standard privacy policy document. Published on website.</li>\n<li>Token Sale Agreement. Two versions available on EOS website (dated 22 June 2017 and 4 September 2017):</li>\n<ul>\n<li>Agreement does not clearly define block.one as a party;</li>\n<li>Governed by Cayman Law;</li>\n<li>Provides for arbitration in the London Court of International Arbitration (LCIA);</li>\n<li>Provides no undertakings whatsoever from block.one and seeks to release block.one from any liability;</li>\n<li>provides for purchasers to waive their rights for class arbitration, class action, or any other type of similar representative proceedings.</li>\n</ul>\n<li>Guides on how to purchase, register, and claim tokens (published on website).</li>\n<li>Sales restrictions and disclaimers (published on website).</li>\n<li>The FAQ provides for further explanations on the use of proceeds and reasons for exclusion of U.S. persons from participating in the ICO. Contains a representation that block.one will hire an independent auditor to confirm that ICO has not been inflated by the block.one team using the proceeds of the ICO's previous rounds to buy further rounds into ICO (published on website).</li>\n</ul>\n<p><strong>Sales restrictions</strong></p>\n<ul>\n<li>EOS Tokens are not offered to U.S. or Chinese persons. This is achieved by the EOS website blocking U.S. and Chinese IP addresses from accessing the token-offering section of the website. Also, by accepting the terms of the token sale agreement, block.one requires each purchaser to represent that they are not a U.S. or a Chinese person, and indemnify the company for any losses that may result from such representations being untrue. The above is all that is done to ensure that U.S. or Chinese investors do not participate in the offering. No passport identification is required to participate in EOS Token offering and confirm the purchaser residency.</li>\n<li>It is also unclear how the US and Chinese sales restrictions are enforced in secondary market and tradings at crypto exchanges.</li>\n</ul>\n<p><strong>Team behind EOS (information from public sources)</strong></p>\n<ul>\n<li>Brendan Blumer, CEO: Involved in the blockchain industry since 2014, serial entrepreneur who has built businesses including trading of virtual currencies in MMORPGs in the US, okay.com in Hong Kong, and 1Group in India.</li>\n<li>Daniel Larimer, CTO: A serial entrepreneur focusing on innovative technologies ranging from virtual reality simulators to second-generation crypto currencies, most notably, BitShares. Dan is a specialist in software development and the inventor of the widely adopted \"Proof of Stake\" and \"Decentralized Autonomous Corporations\" concepts.</li>\n<li>Brock Pierce, Partner: A venture capitalist and entrepreneur who pioneered the market for digital currency in games and has raised more than $200 million for the companies he founded. Brock is the Chairman of the Bitcoin Foundation and co-founder of Blockchain Capital, among others.</li>\n<li>Ian Grigg, Partner: A financial cryptographer who has been building cryptographic ledger platforms for over 20 years, Ian is the inventor of the Ricardian Contract and the co-inventor of Triple-Entry Accounting.</li>\n</ul>\n<p><strong>EOS Software Development Roadmap</strong></p>\n<ul>\n<li>Phase 1 - Minimal Viable Testing Environment - Summer 2017.</li>\n<li>Phase 2 - Minimal Viable Test Network - Fall 2017.</li>\n<li>Phase 3 - Testing &amp; Security Audits - Winter 2017, Spring 2018.</li>\n<li>Phase 4 - Parallel Optimization Summer / Fall 2018.</li>\n<li>Phase 5 - Cluster Implementation The Future.</li>\n<li>There is no undertaking from block.one to stick to this timeline and report on deliverables. In fact, the opposite holds true, as block.one reserves the right to stop developing EOS software at any time.</li>\n</ul>\n<p><strong>Mechanics of EOS Tokens acquisition</strong></p>\n<ul>\n<li>A purchaser needs to register at&nbsp;<a href=\"https://eos.io/instructions\" rel=\"noopener\">https://eos.io/instructions</a>, accept the terms and conditions of the sale of EOS Tokens, and transfer ETH (the min. contribution is 0.01 ETH) from any compatible wallet.</li>\n<li>In order to receive the EOS Tokens, the purchaser needs to claim them from the EOS Distribution Smart Contract once the daily round in which the purchaser participated is over.</li>\n</ul>\n<p><strong>VC/PE Investors participating in the ICO</strong></p>\n<ul>\n<li>According to the press, the following institutional investors participated in the EOS Token distribution: Fenbushi Capital, Blockchain Capital, Li Xia Lai, Michael Cao, Bitfinex, Yunbi, Aurora Investment Advisors, and Hyperchain Capital.</li>\n</ul>\n<p><strong>Some conclusions</strong></p>\n<ul>\n<li>From the legal perspective, the EOS ICO structure is quite controversial.</li>\n<li>The token sale contract does not contain any undertakings or obligations whatsoever from block.one. The only purpose of the sale contract seems to be to provide as many disclaimers as possible to put the token purchasers on notice that they are, in fact, simply donating money to block.one. Purchasers of EOS tokens have more obligations and much greater responsibility towards block.one than block.one itself.</li>\n<li>No practical steps are taken with respect to purchasers' KYC to ensure that there are no &amp;lsquo;dirty money' in the ICO. Block.one simply relies on the purchasers' assurance that they are complying with their local AML regulations.</li>\n<li>The block.one counterparty in the token sale agreement is not defined. No specific company or individual is mentioned, but rather a reference is made to a team of individuals acting under the block.one name. This makes it unclear who is responsible under the contract from the block.one side. This is perhaps less of an issue, given that the contract does not contain any undertaking from the block.one side.</li>\n<li>Block.one structured the offering as donations with EOS tokens representing some sort of receipts confirming the fact of donations. This is uncommon for business entity to receive donations.</li>\n<li>The use of proceeds specified by block.one in the token sale contract and in the FAQ clearly demonstrates that it has nothing to do with the development of EOS Project. There is no clear explanation why block.one needs such a significant amount of money.</li>\n<li>Although block.one takes the view that EOS tokens are not an investment and speculative instruments because they have no value, EOS tokens are traded on a number of exchanges and a significant number of token purchasers participate in the ICO for speculative reasons and arbitrage possibilities.</li>\n<li>There is an attempt to avoid US securities risk (as well as the Chinese ICO ban) by EOS tokens not being offered in these jurisdictions. This attempt is limited to a disclaimer on a website and IP blocking. The EOS tokens, however, become liquid immediately following the offering round and can be sold at exchanges where US and Chinese persons may participate.</li>\n<li>The sale contract provides for LCIA arbitration, which is expensive for a customary retail purchaser. Also, the Cayman Islands are not party to the NY convention on enforcement of arbitral awards, so query as to how the LCIA award will be enforced by token purchasers.</li>\n</ul>",
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      "title": "What are you buying when investing in ICOs? Lawyer's perspective on EOS token offering."
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