Research led by the University of Pennsylvania Professor David Hoffman presents legal literature’s first detailed analysis of the inner workings of Initial Coin Offerings (ICO). Startups are using the novel funding mechanism with increasing frequency. In 2017, an estimate 370 ICOs raised around $6.2 billion, and by July 2018, an additional 430 ICOs had raised almost $17.2 billion. ICOs come with the promise of a “smart contract”, or an automated contract that governs real world relationships where before a legal document would have been employed. Human oversight is supposed to be unnecessary because the embedded code ensures proper governance. But do ICOs actually deliver what they promise? Hoffman’s team examines the white papers of the 50 top grossing ICOs from 2017 and compares the promises made to the underlying code. ICO investors face a unique set of concerns, three of which are addressed in detail: will promotors restrict the supply of their cyryptoasset, will they restrict the transfer of cryptoassets according to a vesting or lock-up plan, and do promotors retain the power to modify the smart-contract code governing the tokens sold? The findings are stark: ICO software code and ICO investor disclosures often did not match. While ICOs are a potentially powerful financial innovation, this failure of self-governance reveals opportunities for policymakers consider options to protect consumers and help the ICO market mature.