Today the SEC announced a consent agreement with Munchee to refund investments in the Munchee ICO. I’ll do a deeper dive into the consent decree in the near future, but for now it’s worth noting how steadily the SEC is ramping up its enforcement strategy. Just a few months ago, the SEC was making phone calls to companies with ICOs, the companies were conducting voluntary returns, and they never heard from the SEC again. Now the SEC is demanding consent agreements – and the necessary but expensive legal advice that comes with entering into them – before it will let a company slip the bit. Everyone that has run an ICO or is thinking about running an ICO should be paying very close attention. And while I am admittedly biased, they should be retaining legal counsel now.