In its recent enforcement action against ICOs, Stefanie Yuen Thio believes that the MAS is reiterating its legal and regulatory position: If you offer a digital token that gives you a right to a return on a regulated form of investment (which could be in the nature of a company share, a debt instrument or a right to participate in profits or revenue from a pool of invested funds), then it falls under the existing regime of capital markets regulation and requires a prospectus. This is to protect investors by ensuring that the fundamental financial, business and risk disclosures are included. Her comments in the article here: https://www.businesstimes.com.sg/banking-finance/mas-turns-up-heat-on-crypto-currency-exchanges-and-icos