This is the slide deck which presents the answer we plan to send to the French regulator AMF. anyone willing to contribute is welcome.

1. Government Blockchain Association – London Chapter
AMF Discussion Paper on Initial Coin Offerings (ICOs)
November 14th, 2017
Thibault Charbonneau
Leila Nassiri-Jamet
Tommy Jamet

2. AMF published a discussion paper on Initial Coin Offerings on October 26, 2017.
The AMF defines ICOs as Initial coin offerings (ICOs) are DLT fundraising operations involving the
issuing of tokens.
The discussion paper describes three stages for an ICO:
- Announcement of the ICO
- Publication of the offering
- Sale of tokens
Participants are invited to send their responses and feedback by December 22, 2017 at the very
latest.
Industry members who want to participate in this discussion can provide GBA with their
answers/comments and GBA will summarise the opinion and share it with the AMF.
AMF Discussion Paper on Initial Coin Offerings (ICOs)
Government Blockchain Association – London Chapter

3. AMF Discussion Paper on Initial Coin Offerings (ICOs)
26/10/2017
AMF issue
Discussion
Paper
14/11/2017
GBA meetup
03/12/2017
GBA Deadline
for sending
responses
22/12/2017
AMF Deadline for
sending
responses
09/12/2017
GBA draft
response
To Participate:
- GBA Slack
- Email: tommy@jamet.co
Government Blockchain Association – London Chapter

4. Regulatory treatment of ICOs by major regulators globally:
• Ban on ICOs: China and South Korea;
• Case-by-case and constant-law basis, with various nuances:
• ESMA (EU), FCA (UK) and FINMA (Switzerland);
• SEC (USA);
• BaFin (Germany);
• MAS (Singapore);
• Other authorities do not regulate ICOs: Australia and Gibraltar;
• Regulated only if sold to retail investors: Lithuania
AMF Discussion Paper on Initial Coin Offerings (ICOs)
Government Blockchain Association – London Chapter

5. Potential regulatory treatment of ICOs by AMF:
AMF Discussion Paper on Initial Coin Offerings (ICOs)
• Option 1: Maintain a regulatory status quo and establish best practices
• Option 2: regulate ICOs using the existing legal framework for prospectuses
• Option 3: adopt an ad hoc regulation tailored to ICOs
 3.A: an authorisation regime applicable to all ICOs available to the public in France
 3.B: an optional authorisation regime
Government Blockchain Association – London Chapter

6. Examples of questions asked by the AMF:
4.1.2 Would you be in favour of having ICO originators comply with principles and best practices?
(list in the discussion paper)
GBA question: What best practices and principles should ICO originator comply with?
4.1.5. Should token investing be restricted to a certain investor type? What type of buyers, if any,
do you believe should not be solicited by ICOs?
4.1.10. Should the starting value of tokens be set solely by the issuer? What rules should apply to
the financial assessment of the token price?
4.1.12. Should the transparency of ICOs be prioritised during the presale and sale period so that
potential investors can find out the funds raised during an ICO in real time?
AMF Discussion Paper on Initial Coin Offerings (ICOs)
Government Blockchain Association – London Chapter