5 THE ITALIAN LAW JOURNAL NO. 2 (2019) The New ICO Intermediaries by Vanessa Villanueva Collao and Verity Winship Smart contracts promise a world without intermediaries. However, that promise has quickly proved elusive, including in the context of Initial Coin Offerings (ICOs), a vehicle for funding startups built on smart contracts and blockchain. Particularly as ICOs attract retail investors who are not code-literate, the question arises: is there a role for new intermediaries? This article assesses the possibility of an ICO auditor, providing a framework for understanding potential audit functions. In particular, it identifies three main roles: to translate the code for retail investors who are not code-sophisticates, to reconcile the code with promises made in other materials aimed at ICO participants, and to verify offline activity and identity where these remain important to the transactions. It then maps these functions onto emerging models. DOI 10.23815/2421-2156.ITALJ ISSN 2421-2156
