If all the promotion and sales of an investment is done overseas, is US brokers license required? - 3rd April,2013.
EB-5 Engagement with the Securities and Exchange Commission - 3rd April,2013.
The answer depends on the circumstances of the person acting as a broker or finder. If the broker is offshore for all aspects of the U.S.-based offering, the SEC will not require broker registration for that individual. But if the individual is U.S.-based and receives transaction-based compensation on the sale offshore of the investment, such as a commission on the sale of the investment, registration may well be required.
Foreign migration agents with no ties to the US do not require broker dealer licence as they promote to foreign buyers in foreign soil. However, if the promoter that is the marketer is a US person or US company even if their promotion activities are being conducted overseas they would need to be licenced.
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