The New ICO Intermediaries

25 Pages Posted: 18 Feb 2020

See all articles by Vanessa Villanueva Collao

Vanessa Villanueva Collao

University of Illinois, College of Law

Verity Winship

University of Illinois College of Law

Date Written: February 18, 2020


Smart contracts promise a world without intermediaries. However, that promise has quickly proved elusive, including in the context of Initial Coin Offerings (ICOs), a vehicle for funding startups built on smart contracts and blockchain. Particularly as ICOs attract retail investors who are not code-literate, the question arises: is there a role for new intermediaries? This article assesses the possibility of an ICO auditor, providing a framework for understanding potential audit functions. In particular, it identifies three main roles: to translate the code for retail investors who are not code-sophisticates, to reconcile the code with promises made in other materials aimed at ICO participants, and to verify offline activity and identity where these remain important to the transactions. It then maps these functions onto emerging models.

Keywords: startups, gatekeepers, tokens, ICO, initial coin offering, securities, auditor, investors, smart contract, blockchain, code, capital markets, CONSOB

JEL Classification: K00, K2, K22, G15

Suggested Citation

Villanueva Collao, Vanessa and Winship, Verity, The New ICO Intermediaries (February 18, 2020). 5 Italian Law Journal 731 (2019), University of Illinois College of Law Legal Studies Research Paper No. 20-12, Available at SSRN:

Vanessa Villanueva Collao (Contact Author)

University of Illinois, College of Law ( email )

United States

Verity Winship

University of Illinois College of Law ( email )

504 E. Pennsylvania Avenue
Champaign, IL 61820
United States
217-244-8161 (Phone)


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