Airdrops and token giveaways of unregistered security tokens is still a securities fraud.<p>You need either to register your token with the SEC, or find an exemption from registration or prove that your token is not a security.<p>If you can prove that your token is not a security, then you can sell it as well (providing you are doing proper KYC/AML and not an MSB or money transmitter.)<p>IANAL
I like the idea,<p>I'm miss one thing:
the minute someone says "I'd buy 100NIL for X ETH", the IFO becomes an ICO no? We just added an extra-step.