The SEC can bring felony charges against individuals offering unregistered securities, not just penalize a corporate entity that created the shares. As I unders

The SEC can bring felony charges against individuals offering unregistered securities, not just penalize a corporate entity that created the shares. As I understand it, it doesn't even matter whether the securities actually are shares of a corporation, or just some similar enough instrument. Before doing this, I would make very sure either the foreign corporation or the foreign market meet exemptions well defended in case law.