Overview
Evan Abrams counsels financial institutions, multinational corporations, and individuals on a variety of international regulatory and compliance matters. He regularly advises clients on issues related to anti-money laundering (AML), economic sanctions, export controls, foreign anti-corruption, the Committee on Foreign Investment in the United States (CFIUS), and the Defense Counterintelligence and Security Agency (DCSA). Among other sectors, his practice focuses on emerging technology, including financial technology (FinTech) where he leverages his deep understanding of business trends and technological developments to help clients achieve their commercial objectives while complying with complex regulatory regimes.
FinTech, Blockchain, Web3, and Metaverse
Evan represents some of the world's largest and most innovative FinTech companies, including entities focused on payments, blockchain and cryptocurrency, Web3, non-fungible tokens (NFTs), prediction markets, decentralized autonomous organizations (DAOs), and the metaverse, among others. He also works with traditional financial institutions such as banks, venture capital firms, and trust companies, including advising them on developing or interacting with new financial technology. In addition to his work with large, well-established FinTech companies, Evan has deep experience working with early stage startups to help them bring novel financial technology to market.
Evan's blockchain and cryptocurrency practice involves representing exchanges, token and stablecoin issuers, NFT creators and exchange platforms, digital asset custodians, and developers of various DAOs and Web3, decentralized finance (DeFi), and metaverse platforms. In a sector where the legal landscape is rapidly changing, Evan helps clients understand both the current state of play and ongoing trends, so companies can be positioned for success now and in the future.
Anti-Money Laundering, Sanctions, and Export Controls
Evan regularly assists financial institutions and others in a wide range of matters related to the Bank Secrecy Act (BSA) and AML regulations promulgated by the Financial Crimes Enforcement Network (FinCEN). This includes helping clients create and implement compliance programs, navigate BSA examinations, and interpret and apply FinCEN regulations. Evan also conducts independent compliance program assessments and advises clients on the applicability of FinCEN regulations, including rules related to money services businesses (MSBs) and money transmitters.
Evan's sanctions and export controls practice includes matters related to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and a variety of sanctions programs under US and international law. He regularly counsels US and foreign clients on complying with those regimes, seeking licenses from relevant agencies, and conducting internal investigations.
Committee on Foreign Investment in the United States
Evan's CFIUS practice involves representing foreign and domestic companies in understanding and navigating CFIUS's regulations, preparing and submitting filings to the committee, responding to CFIUS inquiries, and negotiating and implementing mitigation agreements. He has represented companies in industries including FinTech, energy, semiconductors and electronics, metals and mining, and cyber and digital security, among others. He also assists clients with classified contracts in navigating DCSA requirements related to foreign, ownership, control, or influence (FOCI).
- District of Columbia
- Maryland
- J.D., Georgetown University Law Center, 2016, magna cum laude; Order of the Coif; Senior Articles Editor and Executive Board Member, Georgetown Journal of International Law
- M.Sc., London School of Economics, 2013, with merit
- B.S., Georgetown University, 2012, magna cum laude
Areas of Work
Representative Matters
- Drafted and implemented anti-money laundering (AML) and economic sanctions compliance programs for a variety of FinTech companies.
- Assisted FinTech companies in registering with the Financial Crimes Enforcement Network (FinCEN) as a money services business (MSB).
- Assisted FinTech companies in navigating Bank Secrecy Act (BSA) examinations.
- Assisted non-US companies in understanding the jurisdictional scope of FinCEN and Office of Foreign Assets Control (OFAC) regulations.
- Advised on successful launch of commodity-backed digital token.
- Advised on successful launch of cryptocurrency merchant payment software.
- Advised on successful launch of various NFT platforms and projects.
- Advised on successful launch of multiple DeFi and Web3 platforms.
- Advised clients in a wide range of industries on the mandatory filing requirements of the Committee on Foreign Investment in the United States (CFIUS) and on determining the advisability of submitting filings to CFIUS under the Committee’s voluntary regime.
- Obtained CFIUS approval for transactions across a wide range of industries.
- Assisted venture capital firms in navigating federal rulemaking processes, including those related to FinTech and blockchain, and drafted comment letters for submission to the relevant agencies.
- Conducted internal investigations related to potential sanctions and export controls violations and drafted voluntary self-disclosures for submission to the Directorate of Defense Trade Controls (DDTC), the Bureau of Industry and Security (BIS), and OFAC.
- Assisted clients in seeking removal from sanctions and restrictive trade lists maintained by BIS and OFAC.
Speaking Engagements
- "NFTs for Retailers: A world of promise and peril," myLawCLE Webinar, March 11, 2022
- "BSA/AML Enforcement and Compliance: How to Effectively Mitigate Risks and Perils," The Knowledge Group Webinar, September 22, 2021
- "GBBC Legal and Regulatory Group Update," Global Blockchain Business Council, February 24, 2021
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"Why the Future of Financial Services Blockchain Will Rely on the Legal Industry," Enterprise Ethereum Alliance Panel Discussion, April 18, 2019
News & Publications
StepTechToe
New National Security Rules Targeting Personal Data to Have Significant Impact on AI Industry
March 14, 2024
International Compliance Blog
March 12, 2024
By: Nilin (Irene) He, Evan T. Abrams, Jack R. Hayes, David M. Stetson
Client Alerts
AML Program Requirements for Investment Advisers: FinCEN’s Proposed Rulemaking
February 16, 2024
By: Andrew C. Adams, Coy Garrison, Jack R. Hayes, David M. Stetson, Evan T. Abrams, Sophia Breggia, Vito Arethusa
Press Releases
Steptoe Obtains Trial Victory on Behalf of Client Lattice Semiconductor
February 15, 2024
StepTechToe
Commerce Proposes Significant New Regulations on AI Training and IaaS Providers
January 31, 2024
Steptoe Blockchain Blog
What Does the BTC ETP Approval Mean for the SEC’s Regulatory Approach to Crypto?
January 16, 2024
Publications
CFPB As Pay App Watchdog May Invite More Fintech Regs
January 12, 2024
By: Alan Cohn, Andrew Owens, Coy Garrison, Evan T. Abrams, Sophia Breggia, Vito Arethusa
Resources
Client Alerts
Sanctions Under the Biden Administration: A Return to 'Smart?'
November 24, 2020
By: Edward J. Krauland, Meredith Rathbone, Wendy Wysong, Jack R. Hayes, Peter Jeydel, Evan T. Abrams, Martin Willner, Jordan Cannon (Law Clerk)
Client Alerts
CFIUS Publishes Final Rules Implementing FIRRMA: What Changed and What it Means for Industry
February 13, 2020
Client Alerts
CFIUS Proposes Dramatic Expansion of US Foreign Investment Review, Seeks Public Input
October 2, 2019
By: Stewart A. Baker, Scott A. Sinder, Evan T. Abrams, Martin Willner
Client Alerts
FCPA/Anti-Corruption Developments: 2018 Year in Review
February 28, 2019
By: Lucinda A. Low, Brigida Benitez, William L. Drake, Alexandra Melia, Fernando Q. Merino, Alexandra Baj, Rachel B. Peck, Evan T. Abrams, Katherine M. Dubyak, Lin Yang, Bo Yue, Troy Shephard
Client Alerts
PdVSA Sanctions Designation Has Significant Implications for US Business
February 14, 2019
By: Edward J. Krauland, Meredith Rathbone, Jack R. Hayes, Peter Jeydel, Evan T. Abrams
Client Alerts
Changes Afoot for CFIUS and US Export Controls as the Dust Settles on FIRRMA
August 16, 2018
Client Alerts
June 28, 2018
Client Alerts
FCPA/Anti-Corruption Developments: 2017 Year in Review & 2018 Q1 Preview
April 12, 2018
By: Lucinda A. Low, Brigida Benitez, William L. Drake, Alexandra Baj, Rachel B. Peck, Evan T. Abrams, Galen Kast, Peter Jeydel, Lin Yang, Bo Yue
Client Alerts
New Sanctions Against Russian Oligarchs, Officials, and Companies May Have Significant Impact
April 12, 2018
By: Meredith Rathbone, Edward J. Krauland, Alexandra Baj, Evan T. Abrams
Events
Webinars
Monthly AI, Data & Digital Roundtable
May 16, 2024
Speakers: Evan T. Abrams, Tod Cohen, Andrew Golodny
Noteworthy
- Best Lawyers in America, "One to Watch" (2021-2022)
- Legal 500 US, "Rising Star," International Trade – CFIUS (2023)
Previous Employment
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Co-founder, Political Risk News and Analysis Company
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Law Clerk to the Chairman of the US Senate Judiciary Committee
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Business Strategy and IT Consultant, Anant Corporation
Professional Affiliations
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Co-chair, Enterprise Ethereum Alliance, Task Force on Anti-Money Laundering (2018-2019)
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Member, Association of Certified Anti-Money Laundering Specialists