Blockchain & Cryptocurrency

Steptoe's Blockchain and Cryptocurrency team combines unparalleled legal and regulatory experience across diverse practices with industry-specific knowledge to help clients navigate the complex landscape surrounding cryptocurrencies and crypto-assets in the US and globally.

Our multidisciplinary team includes former high-ranking officials from agencies such as the Department of Justice, Department of Homeland Security, Treasury Department—including the Office of Foreign Assets Control and the Internal Revenue Service —and the Securities and Exchange Commission. These professionals bring extensive experience in digital assets and blockchain technology. Our team offers experience in regulatory areas such as anti-money laundering, economic sanctions, countering the financing of terrorism (CFT) compliance, securities, commodities, and derivatives regulation (covering issuers, exchanges, and investment companies). We also provide guidance on matters including tax law, intellectual property, corporate transactions, public policy, and government enforcement. Whether advising traditional financial institutions, startups, or innovative challenger companies and their investors, Steptoe provides legal and regulatory counsel on issues related to currency, commodities, derivatives, and securities law. Additionally, we offer specialized guidance on the tax implications of activities such as trading, investing, creating and issuing tokens, and digitizing assets.

We take a holistically approach to understanding our clients' business models, operational needs, and competitive challenges. This positions us uniquely to support them in building, acquiring, and operating business entities; developing and implementing regulatory and compliance strategies; and mitigating the legal and regulatory risks associated with emerging technologies.

On behalf of the The Digital Chamber and Coin Center, Steptoe helped establish and continues to serve as counsel on the Blockchain Alliance, a non-profit entity facilitating collaboration between the blockchain and digital asset industry and law enforcement and regulatory agencies. The Alliance fosters open communication and engagement to support the growth of the industry and its technology. Its membership includes more than 60 leading companies in the digital asset space and over 80 local, state, federal, and international government, law enforcement, and regulatory agencies. In addition, Steptoe holds key leadership with several major trade associations and advocacy groups, such as Coin Center, The Digital Chamber, the Blockchain Association, and Global Digital Finance. The firm also co-chairs the Legal and Regulatory Group of the Global Blockchain Business Council.

Steptoe has been recognized a leader in this space by Chambers, the Legal 500 US, Law360, and the National Law Journal, among others.

Our client services fall into four main categories, as further described below, but we are constantly expanding and adapting as the industry evolves.

Noteworthy

Chambers FinTech, Legal: Blockchain & Cryptocurrencies, US (2019-2025)
Legal 500 US, Finance – FinTech (2024-2025)
Legal 500 US, Finance – Fintech: Crypto (2024)
Legal 500 US, Media, Technology and Telecoms - FinTech (2020-2022)

Steptoe advises individuals and entities creating or issuing tokens, as well as with remediating previous token issuances. We advise clients on currency regulation, commodities and securities law, and taxation implications. We also assess the risk of the token and business models and work to proactively develop risk mitigation and remediation strategies.
As necessary, we engage with federal government agencies such as the SEC, CFTC, IRS, and FinCEN, as well as with state regulators, on behalf of clients in order to understand and shape the evolving regulatory landscape and ensure compliance with applicable laws.
We represent leading non-fungible token (NFT) marketplaces and advise retailers and other companies in multiple industries regarding the creation and use of NFTs, including legal and regulatory implications and IP-related issues.
We advise along the full spectrum of digital-asset exchange activities, including formation of digital-asset exchanges, SEC and FINRA broker-dealer licensing and Alternative Trading System registration, CFTC DCO/DCM registration, creation and maintenance of compliance programs, and associated regulatory compliance activities. We also assist with broker-dealer acquisition, including sourcing and due diligence, transaction structuring, change of management requirements for licenses and registrations, and associated processes. We also advise on creation and sale of security tokens, exempt private placement of tokens and tokenized securities, and the Regulation A/A+ process.

Steptoe provides a full suite of services as legal, regulatory, and policy counsel to US and non-US cryptocurrency exchange platforms. We advise exchanges on token listings and issuances, development and launch of derivatives and other products, and acquisitions and other transactional matters. We advise on AML, sanctions, and countering terrorism finance compliance, securities law, commodities regulation, and taxation issues, including tax reporting and foreign tax issues. We defend exchanges and other digital asset companies, and their executives and other personnel, in enforcement and regulatory proceedings as well as in litigation. We serve as strategic advisors, helping exchanges and other entities grow their business while navigating a complex legal and regulatory environment.
Steptoe advises merchants who accept cryptocurrency as payment for products and services. We advise on the mechanics of accepting and storing those funds, the potential risks and mitigation strategies for holding cryptocurrency, and the tax implications.
We advise individuals and entities in setting up cryptocurrency trading platforms, for exchanging between cryptocurrency and fiat or between different cryptocurrencies. We also advise clients on the different business models for trading platforms, including both custodial and non-custodial exchanges, and both centralized and decentralized exchange platforms, as well as over-the-counter platforms. In addition, we advise trading platforms on structuring international arbitrage, taking custody of their customers' private keys, dealing with cyber-threats, and verifying payment, storage, and technology vendors. We have deep experience advising non-US cryptocurrency trading platforms on how to comply with US laws and regulations.
We advise individuals and entities on business models for other crypto and digital asset entities, including issuers and creators of NFTs and stablecoins. We also advise clients on the development and launch of derivatives and other products, and acquisitions and other transactional matters. We are adept at working in highly-regulated industries as well as with early-stage companies and ventures involving digital assets and DLT.
We advise on how to comply with Bank Secrecy Act (BSA), Anti-Money Laundering (AML), and Know Your Customer (KYC) requirements and with economic sanctions regimes. We assist clients in registering as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN), complying with state money transmitter laws and the New York Department of Financial Services (NYDFS) "Bitlicense" regulations, and developing AML policies and procedures. We advise clients on the use of blockchain analytics software for verifying customers' funds and other software for automating AML and KYC processes and digital identity management.
We also advise on the tax implications, reporting regimes, and record collection and retention policies for merchants, trading platforms, miners, and entities paying wages in cryptocurrency. We advise clients and engage with government regulators regarding fiat-to-cryptocurrency conversions, cryptocurrency-to-cryptocurrency conversions, hard-forks, and other taxable events.
Steptoe also advises high-net-worth individuals and entities purchasing and selling cryptocurrency. We conduct due diligence on counterparties such as cryptocurrency exchanges, dealers, and brokers. We guide clients through on-boarding with these entities and assist clients in navigating key decision points when investing in cryptocurrency.
Steptoe represents leading digital asset companies, including stablecoin issuers, digital asset trading platforms, and payments companies in federal and state government investigations. We have handled investigations and enforcement actions undertaken by FinCEN, OFAC, DOJ, SEC, CFTC, IRS, and other relevant federal and state agencies.

Steptoe advises clients on the range of regulatory issues associated with new payments innovations, including issues associated with infrastructure, protocols, applications, services, compliance, and governance. In particular, our team has deep experience advising clients on regulatory issues associated with buying, selling, spending, and cashing out cryptocurrency, blockchain analytics and other transaction surveillance technology, custody services, digital identity, and stablecoins. We are also deeply familiar with the ecosystem of companies and government agencies in this space, as counsel to the Blockchain Alliance and as advisors to, members of, and counsel to organizations such as the Chamber of Digital Commerce, Coin Center, the Blockchain Association, GBBC Digital Finance, and the Global Blockchain Business Council.
Utilizing decades of experience working in and with the legislative, executive, and judicial branches of government, we engage with regulators in order to develop laws and guidance that clarify the regulatory landscape while still encouraging innovation. On behalf of clients, we frequently are involved in all aspects of the rulemaking process, including filing comment letters and advocating before commissioners and staff, as well as international bodies such as the Financial Action Task Force (FATF). We also seek “no-action” or exemptive relief on behalf of clients.

We advise established companies and startups looking to implement enterprise blockchain applications that cross a range of industries such as energy, insurance, real estate, transportation, supply chain, and trade. Steptoe takes a holistic approach to implementing enterprise blockchain applications and developing strategic transition plans to blockchain and distributed ledger technology applications. We consider applicable laws and regulations related to compliance and sanctions, cross-border requirements, tax treatment, data security considerations, and risk assessment of technology vendors and partners, while also anticipating obstacles to implementation.
We conduct impact assessments of blockchain and distributed ledger technologies, including the benefits of public versus permissioned blockchains and the differences among blockchains. We also advise on the legality of smart contracts and transacting digitized assets.
We assess data protection and privacy implications of these enterprise applications. We assist clients in complying with applicable US and international laws and regulations, instituting security systems and procedures to minimize the chances of a cybersecurity incident, developing and improving incident response plans, and providing rapid and comprehensive incident response in the event of a breach or cyber-attack.

Professionals

Jason Abel

Jason Abel leads Steptoe's Campaign Finance and Political Law practice and advises clients on a range of government affairs issues, including legislative strategy and process. Jason served as chief...

Partner

Government Affairs & Public Policy, Campaign Finance & Political Law, Congressional Oversight & Investigations, Vetting & Government Ethics

Washington, DC
+1 202 429 6297

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Evan T. Abrams

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...

Partner

Anti-Money Laundering, Economic Sanctions, Financial Services, Artificial Intelligence

Washington, DC
+1 202 429 3052

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Andrew C. Adams

Andrew Adams, a New York partner, advises companies and individuals in the areas of government and internal investigations, corporate governance, and white collar and regulatory matters. His practice...

Partner

Blockchain & Cryptocurrency, Financial Services, Financial Regulatory Compliance & Policy, White-Collar Defense

New York
+1 212 957 3081

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Vito Arethusa

Vito Arethusa is an associate in Steptoe's GAPP group. He counsels clients in the financial services sector on a variety of regulatory matters, including compliance with regulations related to capital...

Associate

Government Affairs & Public Policy, Financial Services, Financial Regulatory Compliance & Policy, Blockchain & Cryptocurrency

Washington, DC
+1 202 429 8190

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Stephen A. Aschettino

Stephen Aschettino is a partner in the Financial Innovation & Regulation practice, where he leads the Payments team. He is an accomplished business lawyer and trial attorney with more than 20 years of...

Partner

Financial Innovation & Regulation, Payments, Digital Assets and Decentralized Finance, Banking

New York
1 212 506-3928

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Christian M. Auty

Christian Auty advises clients on the full lifecycle of data privacy and cybersecurity matters, from regulatory compliance and risk management to breach response and cross-border data governance, as...

Partner

AI, Data & Digital, Blockchain & Cryptocurrency

Chicago
+1 312 577 1293

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Lauren Azebu

Lauren Azebu has over a decade of experience advising domestic and international clients, including high-net worth individuals, on a broad spectrum of US federal income taxation issues. She regularly...

Partner

Tax, Transactional Tax, International Tax, Private Client

Washington, DC
+1 202 429 3913

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Sophia Breggia

Sophia Breggia counsels clients on a range of regulatory and enforcement matters, primarily in the financial services sector, including those before the Department of Justice (DOJ), the Securities and...

Associate

Financial Innovation & Regulation, Independent & Internal Investigations, Blockchain & Cryptocurrency, Financial Regulatory Compliance & Policy

Washington, DC
+1 202 429 3028

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Spencer Busby

Spencer Busby represents financial institutions, public companies, accounting firms, and other regulated entities in regulatory enforcement matters, internal investigations, and criminal defense...

Associate

Securities Enforcement, White-Collar Defense, Anti-Corruption/FCPA, Independent & Internal Investigations

New York
+1 212 378 7534

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Rachel M. Cannon

Rachel Cannon is a go-to lawyer and creative strategist for individuals and companies facing high-stakes legal challenges. Described by Chambers as "an exceptional litigator," "a true advocate," "...

Partner

White-Collar Defense, Independent & Internal Investigations, Financial Services, Financial Services Litigation

Chicago
+1 312 577 1270

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Representative Matters

Steptoe regularly advises a diverse array of clients on issues relating to cryptocurrencies, crypto-assets, and blockchain technology, including:

Advising leading NFT marketplaces on legal and regulatory issues and engagement with US regulators.
Advising leading retailers and other companies on legal and regulatory issues surrounding issuance and deployment of NFTs.
Representing US and non-US cryptocurrency exchanges in investigations by the US Department of Justice, CFTC, New York Attorney General, and other federal and state government agencies.
Advising non-US companies on the creation and issuance of a token to non-US customers.
Representing a startup in an investigation by the SEC in relation to an initial coin offering.
Advising companies on the remediation of prior token issuances with respect to securities law and currency regulation.
Advising a US company on issues related to privacy coins, including developing an engagement strategy with relevant government agencies.
Advising individuals and institutions on the corporate setup, tax implications, AML/KYC regulations, and process of exchanging cryptocurrency as a broker, dealer, or custodial exchange.
Advising individuals and corporations with respect to tax implications of different investment and entity structures.
Advising prominent retailers on legal and business issues involved in accepting cryptocurrency as payment.
Representing a large cryptocurrency exchange in connection with an investigation relating to a cyberattack.
Representing a blockchain analytics company in connection with government contract-related matters.