Agreed about the steps Stars take nowadays.
Think the main thing which will cause the SEC to go after an exchange will be when some significant-sized asset scams/defaults/fails and the operator and/or victims are in the US. At that stage if they're having to investigate the security it kind of makes sense to go after the exchange at the same time as they'd have to interact with the exchange one way or another whilst gathering evidence. I think that's probably AMC's best change of making headlines in the BTC world tbh - around middle of next year when it becomes apparent investors are in for a large loss to something run from on US soil. They only need 1 US investor for all the foreign registered companies etc to be irrelevant - and AMC gave profit projections in USD so has no 'it's a game' defence to even try to hide behind.
Best defence for those of us actually running investments is to make a profit whenever the outcome of an investment hinges on our own predictions, competence or efforts. That cuts out a lot of potential charges right away. Not being in the US also helps of course.
I doubt that it will take that long for AMC/VMC/AM/Ken Slaughter to get a visit from the folks with black suits and subpoenas. Much of the reason no one has been prosecuted by the SEC up until now is because the SEC has never done it before. Organizational inertia is a major factor in government. Now that the path has been blazed that bitcoin securities offenses can be prosecuted, ambitious folks in the SEC are going to see all the low hanging fruit and go make their careers. And there is no need for the current suckers to actually lose money and complain, a competitor could start the ball rolling just as easily. Do you think Inaba is above dropping a dime on Ken?