Key takeaways

• On July 25, the SEC Division of Enforcement released a report concluding that blockchain tokens sold by the DAO constituted securities.
• As a result, the report determined that registration and other requirements under both the Securities Act and the Exchange Act apply to DAO tokens.
• The report appears to confirm that not all blockchain tokens are securities. However, careful analysis is needed to make sure that any token sale complies with relevant rules and regulations.