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An excellent short insight post by our friend Daniel Glazer pertaining to ICOs and whether or not to register under the Securities Act of 1933, sell only to accredited investors, and KYC / AML obligations of money services businesses.
Sponsors can become money services businesses by, among other things, dealing in currency or transmitting money. Money services businesses are subject to a wide range of federal and state regulations, including anti-money laundering and "know-your-customer" provisions, privacy laws, licensing requirements, and other regulations. Some sponsors may be able to take advantage of exemptions from these regulations—for example, for money transmitters that facilitate the purchase and sale of goods and services—depending on how an ICO and coin transactions are structured.
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