The New ICO Intermediaries

Vanessa Villanueva Collao, Verity Winship

Research output: Contribution to journalArticlepeer-review


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.

Original languageEnglish (US)
Pages (from-to)731-755
Number of pages25
JournalItalian Law Journal
Issue number2
StatePublished - 2019


  • startups
  • gatekeepers
  • tokens
  • ICO
  • initial coin offering
  • securities
  • auditor
  • investors
  • smart contract
  • blockchain
  • code
  • capital markets

ASJC Scopus subject areas

  • Cultural Studies
  • Law


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