Client Alert: The Behring Decision and the Rollback in the Minimum EB-5 Investment

You have no doubt read about the decision in Behring v. Wolfe invalidating the 2019 regulations of the EB-5 Program. The decision rolls back the minimum investment amount from $900,000 to $500,000 (and from $1,800,000 to $1,000,000 outside of targeted employment areas). The decision also invalidated the USCIS’s…

The SEC Fires a Warning Shot Against Celebrity Endorsements of ICO Investments

As the price of Bitcoin reaches record heights and a torrent of money floods into Initial Coin Offerings (“ICOs”), the U.S. Securities & Exchange Commission (“SEC”) issued a statement on Wednesday, November 1, 2017 warning investors to be wary of “celebrities and others” promoting investments in ICOs.  See …

Concurrent Reg D & Reg S ICOs

  Initial coin offerings are all the craze, and for good reason. According to CoinSchedule, over $3 billion has been raised in the first 10 months of October. The Securities Exchange Commission released an investigative report concluding that DAO tokens were securities, and that scared people for maybe a few…

ICO Trend of Disallowing US Based Investors

An increasing number of ICOs are choosing to disallow US investors from participating.  For those of you on those management teams, or those of you with connections to those teams, I urge you to consider the following: 1) Presumably, disallowing US based investors is for the purposes of…