On April 3, 2019, the U.S. Securities and Exchange Commission (SEC) took their first step towards providing greater clarity on the key question of how to evaluate whether transactions involving issuance or sales of digital tokens are sales of securities subject to U.S. securities laws and regulations. The guidance was released in two parts: First, the SEC’s Strategic Hub for Innovation and Financial Technology (FinHub) published the “Framework for ‘Investment Contract’ Analysis of Digital Assets”…