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Blockchain and Money Transmission: A New Horizon for Token-Driven Startups?

Insight Sam Miller Sam Miller · April 09, 2019

Tokens, security tokens, cryptocurrency, or however you wish to define the digital asset which distributed ledger technology has now allowed us to pull from ether, puts issuers and exchangers of this value within the cross-hairs of both Federal and State money transmitter regulation. The question becomes then whether token-driven blockchain businesses that mint and sell utility tokens for use on their platforms outside the context of an Initial Coin Offering (ICO) should fall within the ambit of ‘money transmitters’ as defined in the Federal and State regulatory regimes.  There are a number of bills making their way through Congress, including the Token Taxonomy Bill, seeking to exclude certain digital tokens from ‘security’ treatment, and now, most recently the new Blockchain Regulatory Certainty Bill, introduced by Representative Tom Emmer (Minnesota). This article explores possible interpretations of the scope of the existing regimes, and the need for legislative intervention. Read Sam Miller's full article on Medium.com.


Sam Miller, Rimon Corporate Partner, advises clients in acquisitions and disposals, corporate finance, corporate and partnership structuring and shareholder, operating and buy-sell agreements, general corporate matters, supply, distribution, consignment and inventory management arrangements, and other commercial transactions. He has extensive experience in the metals and transportation industries as well as with technology start-ups, particularly token-driven blockchain businesses, and also advises clients active in the fine art markets. Sam is licensed in California, England and Wales, and South Africa, with specific expertise in all three jurisdictions. He is adept in helping his clients navigate the intricacies of cross-border business and inward investment. Sam has advised clients in a range of countries, including England, Spain, France, Turkey, Lithuania, Latvia, United Arab Emirates, Israel, South Africa, Hong Kong, South Korea, and the United States. Read more.