A district judge in the Southern District of New York rejected Telegram's request for the possibility of issuing its GRAM tokens to non-US investors. The court considers that tokens to US citizens can enter through the secondary market.
https://www.coindesk.com/judge-denies-telegrams-request-to-issue-gram-tokens-to-non-us-investors
https://www.coindesk.com/judge-denies-telegrams-request-to-issue-gram-tokens-to-non-us-investors