Curriculum·G703 Disclosure Ethics and How Crypto Educators Get Compromised·about 32 min

The compensated voice

By the end of this lesson you can

→State what the Commission found in the Kardashian order, what she was paid, what she paid, and what the violation was
→Explain why the violation was the undisclosed payment rather than anything false in the post, and what the anti-touting provision requires
→Compute the ratio of the penalty to the payment, and what that ratio means for anyone deciding whether an undisclosed promotion is worth it
→Identify every form of compensation a crypto educator can receive, including the ones that do not look like payment, and say which require disclosure

Graduate · enrolled learners

This lesson opens with SEC v. Kim Kardashian, 3 October 2022.

What happened: The Securities and Exchange Commission announced charges against Kim Kardashian for touting on social media a crypto asset security offered and sold by EthereumMax without disclosing the payment she received for the promotion. The order found that she had been paid $250,000 to publish a post on her Instagram account about EMAX tokens; the post contained a link to the EthereumMax website with instructions for buying the tokens. She agreed to settle, without admitting or denying the findings, to pay $1.26 million in penalties, disgorgement and interest, to cooperate with the Commission's investigation, and not to promote any crypto asset security for three years. The Commission's statement was that the case was a reminder that a celebrity's endorsement does not mean a product is suitable for all investors, and that federal law requires anyone promoting a security to disclose the nature, source and amount of compensation.
The decision point: Nothing in the post was alleged to be false. The post said what the token was and where to buy it, and it was the kind of post the account published every day. The violation was the $250,000 that the reader could not see, because the reader would have weighed the post differently had they known the poster was paid to write it. That is the whole of the anti-touting rule: the audience is entitled to know that the voice is compensated, so that they can discount it. A crypto educator is a voice that an audience has decided to trust, which makes the undisclosed payment worth more to the payer and the disclosure worth more to the audience, and per this Academy's own policy the only way to hold that trust is to disclose everything, in the lesson, at the point the audience is deciding.
Recorded loss: $1,260,000

What you will be able to answer

→What did the Kardashian order find?
→What does the anti-touting provision require?
→What counts as compensation?
→What is this Academy's policy on paid mentions?

Orientation and Year One are open: anyone can read them without an account. From Year Two onward the lessons are for enrolled learners, because progress through the later years only means anything if it is tracked against a record.

It is free. We do not sell the list and there is nothing to buy at the end of it.

Enroll, it is free Sign in Start at the beginning

Sources and review

Confidence high·Volatility medium·Reviewed 2026-09-14·Owner unassigned

Contested

Whether EMAX was a security was the Commission's position in the order, which Kardashian settled without admitting or denying. The anti-touting analysis in this lesson applies to anything that is a security; whether a given token is one is a separate question the lesson does not decide.

The loss_usd figure is the settlement amount, not a loss to the public; the order did not quantify investor losses attributable to the post.

← Curriculum Directed silence: when the sponsor tells you not to disclose →