https://www.sec.gov/Archives/edgar/data/1729650/000095017218...
On their own discounts are not illegal.
I think what’s obvious is that the network is not truly decentralized and depends on telegram and investors expect to profit from telegrams work on the network. So they should probably file an s-1 and follow the blockstack route.
What would have been ironic, is if TON was truly decentralized and independent of telegram than the network would have been launched anyways.