This thesis canvasses how the United States, France, and the European Union have approached the issue of whether ICOs should be considered securities offerings for the purpose of applying securities law. It analyzes the existing legal frameworks in the United States and France as well as prospective laws and regulations that are currently being discussed by the United States Congress and the French Parliament. In both countries, legislators have refrained from legislating on the subject, which has contributed to legal uncertainty. Nevertheless, some laws were passed fairly early on in order to stop the proliferation of ICOs. At this stage, however, prospective legislation is being proposed to replace existing, prohibitive laws, which would create conditions that are more conducive to ICOs.