A great deal has been written about initial coin offerings
(ICOs) and other token generation events (TGEs) (collectively in
this article "TGEs" and the entities that undertake them,
the "Issuer") in terms of ensuring that regulators
adequately apply and enforce investor protection measures and
protect global capital flows from contamination with proceeds of
crime, both issues which many fear may result from the
proliferation in use of cryptocurrencies and TGEs.
The attendant scrutiny and debate over the correct
classification of digital tokens and the extent to which their
offering and issuance should be subjected to traditional securities
regulations is understandable and valuable. However, since the
fundamental corollary to robust and proportionate external
regulatory oversight is robust internal governance, rather than
adding to the commentary on this subject, this article instead
seeks to look specifically at some of the challenges confronting
those who operate
