https://www.natlawreview.com/article/can-sec-bring-enforcement-actions-against-international-schemes https://www.natlawreview.com/article/can-sec-bring-enforcem

https://www.natlawreview.com/article/can-sec-bring-enforcement-actions-against-international-schemes https://www.natlawreview.com/article/can-sec-bring-enforceme... > When the conduct outside the United States had a substantial effect in the United States or upon United States citizens. So, as long as you make sure not to affect the US or US citizens, you should be safe from the SEC. However, who knows how broadly this rule will be read. If you don't KYC, you could accidentally affect a US citizen, and I don't see an exception here for that case. (I don't know if this applies to all SEC rules or just 77q(a), but it seems prudent to assume that if you are running afoul of an SEC rule you be very sure that no US citizen uses your services.)