Addison Cameron-Huff

Robinhood, an American fintech, is sometimes called a "Superapp". A superapp is an app that offers all kinds of financial-related services. In Robinhood's case, they offer everything from literal cash deliveries to your house to stock trading, bank accounts, cryptocurrency dealing, and prediction markets. They're now offering 24/5 trading via MiCA (based in Lithuania) across the EU for tokenized stocks (see my piece on that from last year). They're currently expanding in Canada, and perhaps gearing up to launch the same sort of thing here. Whether it's Robinhood or someone else, what would they need to do to launch a Superapp in Canada?

My neighbour made a bad face when I mentioned I'm a lawyer who advises crypto businesses (and sometimes combats criminals on the civil side). He said he'd met a lot of "those people" in Bali, Indonesia. But he didn't, becuase they're not the same people as the ones I work for and the people who genuinely are making new things. This is a constant problem with the big label of crypto. That's why some businesses turned to the label "blockchain" many years ago. Unfortunately, it's like saying you work in "email", in a world without spam filters, and where journalists write articles treating everything sent by email as "email". If that was the case, we'd all have a negative view of "email" despite its utility. This is not to say they're the same, but rather that with a big enough label it'll include a lot of bad things amongst the good. More fundamentally, the bad stuff has big budgets for ads/marketing, so the good stuff isn't seen.

Far be it from me, a humble lawyer, to tell people about economics. This article is a summary of the thinking of various economists/philosophers, who explained the realities of economics before John Keynes came on the scene in the 1930s with a highly influential book that's still causing problems 90 years later. Having not found a good summary of why the The General Theory Of Employment, Interest And Money can't be right, I put together this piece. My first intuition about the book was based on its logical problems and bad writing, but further reflection led me to write up a note for myself that became this blog post. If you enjoyed this, please send me an email to let me know: addison@cameronhuff.com. My unique contributions in this article are, beyond the synthesis of various viewpoints, the doctor prescribing bronzer example in section 5 and the geometric analogy of a circle in a square in section 13.

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My main job is helping people to build great companies. Often that involves figuring out what licenses apply, obtaining them, and helping to build out long-term compliance programs. Sometimes that involves international structures or working with lawyer colleagues in other jurisdictions. But every once in a while, someone hires me to investigate a large financial fraud. Typically these are investment frauds, and usually I'm acting for a victim but it can also be for a regulated platform that is involved in the issue (e.g. customer thefts carried out by insider or a partner company fails suddenly). When it comes to investigating fraud and wrongdoing, it's very helpful to know what the right thing looks like, because then the wrong thing jumps out. This blog post explains some of the ways I do this.

What Do I Know?

I've written easily over a hundred terms of use agreements for my clients. When the lawyer's done, they send it to the client, and tell them to add a checkbox to their signup flow that says: "[ ] I agree to the Terms Of Use Agreement", with the agreement title being hyperlinked, usually to a PDF or sometimes a webpage. This is great. On day 1: everything works. This blog post is about what happens after day 1.

Two Important Things That Are Usually Missed

Kirkland Ellis, one of the world's richest law firms, claims to be investing $500m into building their own law AI platform. They're joining a rush of startups, VC, and law firms that are all building affordable legal services using AI. The dream is to replace expensive lawyers with cheap software. Or, if AI can't do the job on its own: to turn $200 lawyers into $1000 lawyers.

Why can't $200 lawyers be $1000 lawyers? Why can't $100 bankers be $1000 bankers? All of these platforms are being built with an understanding that amazing quality work can be produced at a fraction of the cost. Because LLMs are so amazing at coding, math, and meaningless writing, it's widely assumed that this is possible. Having tried for years to make this a reality with my own practice, I have my doubts, and I've written them up here for anyone else who's wondering why this is hard.

This week I launched a new website for my law practice. It better captures how my practice is operating and has a nicer design, aided by ChatGPT v5.

On Monday, I posted about “Bask Wallet”, a crypto wallet I made that demonstrates the coming future of on-chain finance. Why is this interesting? What does this say about what's coming?

I've made a wallet called Bask Wallet (https://baskwallet.com). It enables people to instantly trade SOL/USDC/SPYx, with one-click model portfolios that are applied to the user's assets. It's on-chain, nearly instant, and trades cost about 1 cent via Raydium.

I've completed my series of blog posts about launching a token as a Canadian business, but it's 23000+ words, so probably most people in 2026 aren't going to be reading it, they're going to be LLMing it.

Most of my clients are heavily using LLMs already, and I've even launched my own production Slack bots for contract pre-reviews, regulatory pre-review, etc.

Over the last two weeks, I've published 24000+ words on the topic of launching tokens in Canada. My goal with this series is to challenge the orthodox view that launching a token in Canada is illegal. For years, lawyers have advised their clients to steer clear of Canada. But is that advice well-founded? What's the real state of the law? Has anything changed over the last decade? My thesis is that lawyers and regulators alike have failed to properly understand the nature of tokens, the developments since the 2017/2018 boom, and changing thought south of the border (see part 1). It's up to entrepreneurs to decide if Canada will be the home of the next great thing in crypto but I believe there's no legal barrier to the majority of projects launching here.

These posts capture my experiences working with some of the best lawyers in North America, and seeing how the cases, regulatory decisions, and projects have unfolded.

This is the 10th article in my series on launching tokens in Canada. This post contains some of the practical tips that I've given to token projects over the last few years (all of which have not had any regulatory or private legal actions against them). The goal is to minimize risks while selling, both in the initial phases of a project and later. The latter part of this post concludes by explaining how securities laws impose a useful type of discipline that moves people away from failed projects and short-term thinking. Following the law can be a powerful advantage in the market.

Conservative Rules Of Thumb For Selling

The previous post in this series explains the rule for tokens: NRFM. But what does this mean in practice? What sorts of tokens can be launched in Canada?

14 Legal Token Types

A Canadian token creator needs to know one rule: No ROI From Management. This is the true rule of Pacific Coin and Howey. Token creators in Canada have to take this rule to heart, and they have to think of this rule as they make their systems, because if they obey the rule, they can likely launch their token in Canada without accidentally stepping into the danger zone of securities laws.

Repeat after me: No ROI From Management.

The previous posts in this series (part 1, part 2, part 3, part 4, part 5, and part 6) describe the regulators who have taken an interest in tokens, the applicable legal regimes, the history of those rules, and what provincial securities regulators have said about tokens being securities. Having canvassed this, it's time to look at the American experience, because, under similar legal rules, the federal securities regulator recently issued guidance that surprised many people by saying that a number of types of tokens are permitted.

Clear Guidelines In The US

The previous posts in this series (part 1, part 2, part 3, part 4, and part 5) establish what's regulated and why. The primary issue that's arisen for token creators in Canada has been provincial securities laws but, when properly understood through a neutral lens (i.e. not through the lens of the regulator itself) is far more limited than most people understand. To put this altogether, I've explained below what the special categories of tokens are that have challenging legal regimes that apply. Despite what most people think, Canada is still a country generally governed by the rule of law, and the rule of law is that if something is not forbidden then it's permitted. If there is no legal reason why a token can't be launched, then it can. Below are some special situations where maybe they can't be launched. Or, if they can be, that there's significant rules that are relevant to the viability of doing this in Canada.

The special categories that are danger zones are:

In part four and part three we saw that the OSC and other provincial securities regulator regulate the raising of capital. The key learning here is that if a token is a stand-in for a thing that is regulated, then that token will be regulated just like the thing it stands in for. If I make a token that is redeemable for narcotics, that'll be unlawful, but only because the dealing in narcotics is regulated. Similarly, if a token represents a capital raise, or the token in combination with other things is sufficiently similar to a capital raise, then that's where the securities regulators will get involved.

Raising Capital Or Earning Revenue?

Part three of this series looked at the historical origins of the modern approach to interpreting what a security is. Now that we know how the courts have decided the fundamental issue for orange groves and bags of coins, we can look at how regulators have applied this to digital assets. (If any of the terms below are unfamiliar, please go back and read part three and this will make more sense).

Below is a complex dive into regulatory guidance. Keep in mind what all of this shows: the OSC has never said that all crypto is a security, and they have consistently referred to tokens in reference to “raising capital”, which few disagree is a regulated activity. The guidance isn't wrong, it's the interpretation of that guidance that is. Furthermore, in the application of this guidance, there isn't one decided case to point to that says whether any non-stablecoin token is a security, other than in connection with an investment/fraud scheme. But there is a 2024 CMT decision that suggest the OSC has pushed beyond the bounds of the law in their characterization of tokens.

Part two of this series dealt with federal regulators in Canada, which is a relatively simple story: they're simply not very relevant to a company launching a token (unless it's a stablecoin). This part deals with the thornier topic of securities regulators, who have been the most vocal governmental opponents of new token launches.

Understanding The Securities Regulator Dilemma

In the first part of this series I noted some of the reasons why the time is right to think about launching a token in Canada. The enormous change in the posture of American regulators (without underlying legislative action) is the reason to think that the same will one day happen in Canada. But the starting point for understanding why things have changed is to look at how things were. Anyone with a deep understanding of the regulatory guidance and applicable laws, like loyal readers of this blog, may want to skip to part four of this series (part three concerns securities laws).

Why Do People Think You Can't Launch A Token In Canada?