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What Preventative Compliance Measures Can a Company Take to Avoid a Cease and Desist Order?

The company should conduct a thorough legal analysis (Howey Test) to ensure the token is structured as a utility, not a security. This includes rigorous vetting of all marketing materials to avoid promising investment returns.

Implementing robust Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures is also critical. Finally, seeking a no-action letter or utilizing a regulatory sandbox provides a proactive defense.

How Have Recent SEC Enforcement Actions Clarified the Application of the Howey Test to Tokens?
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What Are the Key Differences between Institutional and Retail KYC/AML Procedures?