Thanks for reply and nice links.
I am assuming that, it is supposed to be US-residents. I US/China residents are excluded (as will be written in TnC) from ICO sale, these complication will not come into picture ?
I am looking at having this token as security, but not selling it to US residents. Many investors (even outside US) prefer to go only with Security tokens. That is the reason, looking possibilities in this option.
If you're not selling to US residents, then the Reg D restrictions don't apply.
However, it's definitely not enough to simply write in the terms and conditions that US residents are prohibited. You likely need to go further than restricting US IP addresses too. You'll need an adequate KYC screening process to keep out US investors. If you don't implement it carefully, you may run into problems from federal
or state regulators,
like this:
In his defense, Bensonoff raised the fact that the tokens are not available for sale to U.S. citizens and that screening procedures had been established to ensure that sales would not be made to U.S. residents. However, the Division found that the screening procedures were inadequate to prevent the sale of Caviar tokens to U.S. residents, noting that at least two U.S. residents were approved to participate in the ICO. The complaint further describes the types of general solicitation Bensonoff and Caviar used to promote the ICO, including websites and other social media platforms (including those of third party promoters) that are accessible by investors in the United States.