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An initial token offering (ITO) is a fundraising mechanism based on the issuance and distribution of virtual tokens using blockchain technology. Depending on the token’s economic model, the rights it confers, and the structure of the offering, an ITO may fall under virtual asset and/or securities regulations, as well as anti-money laundering and counter-terrorist financing (AML/CFT) requirements.
Mirsatori provides end-to-end legal and regulatory services for structuring and implementing ITO projects—from preliminary legal analysis through token offering launch and ongoing support for the project’s operations in the selected jurisdiction.
Get an Initial Token Offering (ITO) guide with answers to the key questions
Within the framework of the Virtual Asset and Initial Token Offering Services Act 2021 (VAITOS Act 2021), Mirsatori provides comprehensive legal and regulatory support for virtual asset and ITO projects, including:
Assessment of readiness under the VAITOS Act 2021 and related AML/CFT obligations, identification of non-compliances, and preparation of a corrective action plan.
Preparation of the application package, support with filing, communications with the competent authority, and support throughout the review process.
Design of the issuer/operator structure (entities), allocation of roles and functions, and preparation of corporate resolutions and agreements.
White paper, disclosures, risk factors, terms and conditions, privacy policy, and related documents; where required, SEO-aligned drafting (wording and structure) without compromising disclosure completeness or legal/regulatory accuracy.
Determination of the token’s legal nature (including the risk of being classified as a security or other regulated instrument) and structuring aligned with the resulting regulatory implications.
Client and counterparty due diligence, sanctions screening, transaction monitoring, data retention, and reporting.
Support with continuing obligations (updates, notifications, periodic reporting, maintenance of policies/procedures), preparation for regulatory inquiries, and alignment with bank compliance requirements.
Legal assessment of your token offering model, white paper, and VASP licensing prospects in Mauritius under the Virtual Asset and Initial Token Offering Services Act 2021.
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The assessment covers the token’s legal classification, analysis of applicable regulation, licensing requirements, project structuring, and core compliance obligations (AML/KYC, disclosures, sanctions constraints).
Not always as a formal requirement. In practice, however, it helps identify regulatory risks early and avoid breaches that may lead to licensing refusal, bank de-risking/blocking, or regulatory enforcement.
Yes. A preliminary assessment is recommended before finalizing the white paper to align the economic model, tokenomics, and disclosures with applicable regulatory requirements.
No. A legal assessment does not replace licensing. It establishes the legal basis and a roadmap needed for a compliant ITO launch and subsequent engagement with regulators.
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