LEGAL

It is difficult to follow the rules when nobody actually knows the rules. While the SEC has not given direct guidance to ICOs, it is easy to gauge their temperament, therefore, Apollo18 is taking as many steps possible to align ourselves as a security offering. This means there are a few rules and guidelines we must follow moving forward with the Initial Coin Offering as detailed below:

SEC REGULATION D

Apollo18 has been utilizing SEC Regulation D as a guide for launching our Initial Coin Offering. Rules 504 and Rule 506 allows us to raise money from an unlimited number of accredited investors up to $5,000,000. Utilizing two separate entities, each entity will raise no more than $5,000,000. After the first sale is initiated, Apollo18 has 15 days to file Form D with the SEC and intends to within the time limit.

ACCREDITED INVESTORS

Due to the Rule 506 of Regulation D, Apollo18 may only accept investments from accredited investors. An accredited investor is a natural person that has an income of $200,000 ($300,000 together with a spouse) or more for two consecutive years OR has a net worth over $1,000,000 excluding the value of the person’s primary residence.

Regulation D also allows Apollo18 to raise funds from up to 35 non-accredited investors. All non-accredited investors must be “sophisticated.” The SEC defines this as having “sufficient knowledge and experience in financial and business matters to make them capable of evaluating the merits and risks of the prospective investment.”

Due to the anonymity of the blockchain and the state of cryptocurrency, it is not possible to feasibly verify each individual investor’s net worth. In addition to this, it is well known that cryptocurrency is a very volatile and risky environment. There is a safe assumption made that an investor is educated in the risks associated with cryptocurrency investments.

PARTNER SALE

The Apollo18 Partner Sale was launched by The Apollo Project, LLC. The Apollo Project followed the Regulation Crowdsale Compliance Guide as detailed on the SEC website. The Partner Sale was capped at $1,000,000 and partner tokens are to be held for 6 months. At the launch of the ICO, this 6 month vesting period will be over.