1. Thank you for your interest in ATFS Project.
2. In preparation for the ICO, ATFS has reviewed the announcements and key regulations of ICO-related regulatory authorities in as many countries as possible, but nevertheless, there was a limit in order to examine and review all the detailed laws and regulations of all countries in detail.
3. Therefore, except in cases where it is possible to ascertain the clear disclosure and legal content of the government and financial regulatory authorities in relation to ICOs, like United States, we have written T&Cs primarily in accordance with the ICO notices and guidelines of the government.
4. In the case of Singapore, we deemed Token Issue of Offer prohibited for Singaporeans according to MAS’s guidelines when we announced our ICO schedule.
5. However, MAS’s released a revised guideline, “A Guide to Digital Token Offerings” at the end of November 2017. After reviewing this new guide, our legal advisor suggested that Singaporeans can also participate in ATFS ICO.
The basis of the interpretation is as follows:
- First, under the MAS guidelines, the laws related to the Token Issuance in Singapore are the SFA (Securities & Futures Act) and FAA (Financial Advisers Act).
- In relation to section 2 of the MAS Guidelines (Application of securities laws on offers of digital tokes in Singapore), ATFS is not subject to the provisions as our headquarters is established in Cayman Islands and not Singapore.
- In relation to section 3 (Money laundering and financing of terrorism concerns), ATFS ICO consists of strict KYC.
- Participation in ATFS ICO does not apply to any of the case studies presented in section 4 (Illustrations of securities laws to offer or issues of digital tokens). There are references to “receiving profits” in case 3, but it is understood that there is a problem if the Token Issuance is aimed at “investment in a portfolio of shares”, and this is irrelevant to ATFS’s nature of business such as Smart Farm 2.0 and R&D Center.
6. Nevertheless, please note that the above interpretations and opinions do not constitute legal guarantees, and please be advised that decisions and liabilities are on the investor.
Please check out updated Terms & Conditions before investing.
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