Tokenized Investment Structure for Online Casino

A licensed online casino operator ran a complex international structure with licenses from Curaçao, Anjouan, and the Canton of Zug. To fund platform development and scaling, the client planned a tokenized fundraising round — issuing utility tokens pegged to USD, with each token granting a contractual right to a monthly share of casino profits. The model touched crypto, securities, and tax regimes across three jurisdictions at once, with a cross-border investor base on the other side. The client needed a Token Sale Agreement robust enough to anchor investor relations and survive regulatory scrutiny — before opening the round to capital.

We structured the legal foundation of the token offering end-to-end:

1. Tokenomics review — conducted a deep analysis of the client's tokenomics and business model, with a legal review of the whitepaper and a structured Q&A with the founding team.
2. Cross-border structuring — mapped the offering across Switzerland, Curaçao, and the Comoros, aligning the model with applicable crypto, tax, and securities regimes for a diverse investor audience.
3. Token Sale Agreement — drafted a comprehensive agreement covering acquisition process, investor eligibility, rights and duties of token holders, tokenomics mechanics, taxation clauses, and AML and risk disclosures.
4. Investor-relations anchor — shaped the agreement as the foundational document for token holder relations, with clear allocation of rights and obligations and effective risk mitigation built into each section.