KYC, AML, CTF, Regulation and Utility Tokens - An academic discussion

[ChrisHM]

I want to attempt to have an introductory discussion on the regulation of utility tokens  My first attempt at an outline of issues/questions is as follows:

1.  Utility tokens are similar to Starbucks gift certificates.  They are essentially currency you can use to buy goods and services in a given shopping universe.
2.  If we regulate the sale of utility tokens, (a) ICO issuer would be responsible for the initial sale and (b) exchanges would be responsible for resales.
3.  On that basis, KYC, AML and CTF checks would be done by the ICO issuer at the time of the initial sale, and likely by the exchanges thereafter.
4.  The ICO issuer cannot have responsibility for KYC after the ICO.  Much like Starbucks cannot and does not track who owns a starbucks gift certificate.
5.  There is no de minimis exemption (that allows you to skip KYC) for sales of tokens below a certain threshold.
6.  The reason to distinguish transactions in starbucks gift certificates vs utility tokens is a Government choice.

 
Any thoughts?