On 31 July 2019, the Financial Markets Law Committee (FMLC) published a paper identifying issues of legal uncertainty arising from initial coin offerings (ICOs).

The FMLC examines the legality of ICOs in different jurisdictions emphasising the lack of international harmonisation and varied approaches to regulation and considers the exploratory work required to provide certainty for financial markets and regulators. In section 2 of the paper, the FMLC gives an overview of ICOs and the proposed categorisation standards. Section 3 details the legal uncertainties that arise from framing ICOs under specialised regimes. Section 4 considers the potential impact of such uncertainties and section 5 proposes possible solutions