China banned investment in ICOs citing breaches of securities laws and “disruption to economic and financial order”13, and moved to shut down cryptocurrency exchanges also.13 In July, the U.S. Securities and Exchange Commission required companies to register ICOs in the same fashion as IPOs14. Following this ruling on September 29th, the SEC charged two companies with fraud and selling unregistered securities after running successful ICOs that collected more than $300,000 USD14.Substantial efforts have been made to legitimise cryptocurrency offerings by law firms such as Cooley in New York and others with vested interests in making ICOs work. Cooley attests that it has developed a “simple agreement for future tokens” (SAFT) framework that will allow token sales to be compliant with US securities laws. This is important given that several major ICOs had excluded US individuals from participating given the then-standing issues with the SEC. If by applying the SAFT framework the SEC is satisfied, then US investors would have access to more ICOs providing a major source of capital to them. The basic premise of the Simple Agreement of Future Tokens (SAFT) is that the cryptotoken fail the Howey test, a measure of whether a financial instrument is in fact a security. In order for tokens to fail the test and not be considered securities, they must be delivered to investors only after a functioning product or service is in place. “The network and the token must be genuinely useful such that they are actually used on a functional network,” according to Cooley’s framework. To date ICOs have delivered tokens to investors before the launch of the underlying currency, meaning that the only real function tokens could have use for would be in trading in secondary markets, blatantly classifying them as securities.