Initial Coin Offerings (ICOs) represent a potentially important innovation in corporate finance: a vehicle for raising liquid venture capital utilizing modern technology.  Yet the current environment resembles crowdfunding on methamphetamines.  Widespread abuses demonstrate the need for investor protection.  Rather than focusing on the question of which current regulatory round hole these square peg crypto-asset offerings should be crammed into, this discussion will instead address what the regulatory environment should be if it were designed from scratch.