I haven't been following closely, recently, but literally the first one I checked has no check on residency [0], which is enough to bring it under SEC jurisdiction if the sale goes over other thresholds.[1]

Sales before and after the bulletin are subject to the same laws.

[0] https://etherparty.io/ico/contribute

[1] https://www.sec.gov/divisions/corpfin/internatl/foreign-priv...