Don't you think you could argue that the Utrust token can be seen as a "payment instrument" and therefore would require AML and KYC obligations for the ICO?
At this point no, because there is nothing you can buy with them. In the future, perhaps yes, if they can be used in a payment system. From the utrust whitepaper:
Once all the regulatory questions have been clarified with the Swiss Regulator (FINMA), the UTRUST platform will be a payment system that will enable you to use the token and spend it independently alongside a system that grows in synergy with the token.
In their own words, only
after they received their answers from FINMA to regulatory questions, will it be possible to use them in payment transactions.