Initial Free Offerings as an Alternative to ICOs
medium.com
medium.com
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.
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.)
IANAL
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.