Russell Bruemmer former top lawyer of the U.S. Central Intelligence Agency (CIA) and the former lead of the congressional affairs unit at the FBI, Bruemmer gained the relevant experience working for decades at for the law firm of WilmerHale, helping traditional companies structure their corporate governance. Now he is taking it upon himself to help token issuers construct compliant initial coin offerings (ICOs).
While that might sound challenging in a space where the regulatory framework has not been formalized, Bruemmer is as prepared as anyone could be in his new role advising blockchain startup Applied Philosophy Labs (APL).
In recent years, he said, he was approached by a number of blockchain entrepreneurs trying to figure out if the token they wanted to issue was a security or not.
In a climate where the Securities and Exchange Commission has been cracking down on crypto token fundraising schemes, Bruemmer knows he has his work cut out for him.
At APL specifically, he has helped the public benefit corporation draw up plans for a network of humanitarian companies that would sit underneath the parent entity and issue regulated cryptocurrency tokens.
To fund the humanitarian companies, he helped create a template to comply with the SEC’s Reg CF and Reg A+. The hope is that, eventually, this compliant structure will define a path to public offerings via an S-1 filing and S-3 filing.
Bruemmer told CoinDesk:
“We are using corporate and governance structures that will be familiar to, and thus comfortable for, our investors. This is another aspect of our intention to be transparent with our investors and regulators who have jurisdiction over our activities.”