Excellent.. finally someone referencing to the Howey test:
https://www.investopedia.com/terms/h/howey-test.asp
Another test is in simplified terms this:
If it looks like a dog, behaves like a dog and smells like a dog - it is a dog.

So actually you would have to consult a lawyer in the jurisdiction where you want to incorporate your venture and also a lawyer in every jurisdiction of a person living in you want to sell your token to.
Else you would not be able to get a reliable statement..

Having said this, this is what most likely will happen if you actually do this:
You will incur enormous bills from lawyers and you will get totally contradicting statements of those lawyers because this whole complex is still so new and fresh that there are no precedents or cases at superior courts you can reference to and also no clear cases of the big watch dogs as of this very moment.
So the only reasonable advice a non lawyer could give is:

do not do it!..

.. and if you still want to do it and take the possible risk, IMHO: abate the risk as much as possible.
Those abatement measures could be:
1.) Do not scam or mislead people! (this should be self explaining)
2.) Do not sell tokens for fiat
3.) Do not sell to people in certain jurisdictions as the likes of US/ UK / Japan / China / Kanada etc.
4.) Do not promise any "investment returns"
5.) Do not offer asset backed tokens but only utility tokens and explain the utility use of the tokens
6.) Stay small in regards of numbers of people you are selling the token to and in regards to overall volume raised
etc. etc. etc.