Overview
Alan Cohn counsels clients on a range of blockchain- and cryptocurrency-related issues, from regulatory best practices for cryptocurrency companies to legal issues associated with novel uses of blockchain technology. In addition to co-leading Steptoe's Blockchain & Cryptocurrency practice, Alan also co-leads the firm's National and Homeland Security practice, and has experience across homeland security, emergency management, and emergency response services at the federal and local level.
Blockchain & Cryptocurrency
Alan represents a variety of different types of entities focusing on blockchain and cryptocurrency, from cryptocurrency trading platforms to investment funds to startups developing new blockchain protocols, as well as corporations interested in exploring potential applications of blockchain technology. Alan helped found Steptoe's Blockchain and Cryptocurrency practice and serves as its co-chair. Alan also serves as counsel to the Blockchain Alliance, a public-private forum established by a broad coalition of companies and organizations to help combat criminal activity on the blockchain, and advises companies and investors concerning a range of issues associated with the adoption and use of blockchain and distributed ledger technology. Alan is ranked among the top US lawyers in Blockchain and Cryptocurrencies by Chambers USA (2019-2022), where he is noted for his "tremendous depth of expertise in regulatory issues facing blockchain platforms and cryptocurrencies." He is also recognized as an MVP in FinTech by Law360 (2019), a trailblazer in both Cryptocurrency, Blockchain & FinTech (2018) and Cybersecurity (2017) by National Law Journal and as a Next Generation Lawyer in Cyber Law by The Legal 500 (2017-2019). Alan brings a unique perspective, focusing on the intersection of cryptocurrency and blockchain technology with cybersecurity and cybercrime, and advising clients on national security and emerging technology issues.
National and Homeland Security
Before joining Steptoe, Alan served as a career official in senior policy positions at The Department of Homeland Security (DHS) for almost a decade, during both the George W. Bush and Barack Obama administrations. Most recently, he served as the Assistant Secretary for Strategy, Planning, Analysis & Risk and second-in-charge overall of the DHS Office of Policy during the second term of the Obama Administration. Among a variety of responsibilities, Alan established the cyber policy office within the DHS Office of Policy, represented DHS on the Committee on Foreign Investments in the United States (CFIUS) and related national security review processes for foreign investments, and architected and helped implement DHS Secretary Jeh Johnson's Unity of Effort Initiative, a major corporate-level DHS management reform effort. Alan also oversaw emergency preparedness and response policy for the DHS Office of Policy, and participated in and helped run a variety of scenario planning and tabletop exercise activities at DHS.
- District of Columbia
- Maryland
- J.D., Georgetown University Law Center, 1997, cum laude
- A.B., Columbia University, 1993, History and Political Science
Areas of Work
Representative Matters
- Advising global cryptocurrency exchanges on legal and regulatory issues.
- Serving as cryptocurrency and crypto-asset regulatory counsel to investors and investment funds.
- Advising blockchain companies on steps to remediate pre-sales of cryptographic tokens.
- Advising leading early-stage cryptocurrency and crypto-asset companies on legal, regulatory, and policy matters.
Speaking Engagements
- “From Constraints to Catalysts: Regulation’s Role in Blockchain Innovation,” GBBC’s 7thAnnual Blockchain Central Davos, January 17, 2024
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"Cryptocurrency Fraud: What Banking Business, and Securities Lawyers Need to Know," ALI CLE Webinar, September 29, 2022
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"White House Framework for Responsible Development of Digital Assets," Global Blockchain Business Council (GBBC) Blockchain Central UNGA, New York City, September 20, 2022
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Moderator, "Regulatory and Enforcement Panel," Web3 Summit hosted by American University's Kogod School of Business, September 14, 2022
- "NFTs for Retailers: A world of promise and peril," myLawCLE Webinar, March 11, 2022
- "Navigating the Cryptocurrency Enforcement Framework from US Department of Justice and Regulators – Domestically and Abroad," Lexology Webinar, April 8, 2021
- Moderator, "The Great Crypto Transition: FinCEN, Gamestop, The States & More," Chamber of Digital Commerce's Parallel Live, February 25, 2021
- Moderator, "GBBC Legal and Regulatory Group Update," Global Blockchain Business Council, February 24, 2021
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"Regulation of Emergencies," London School of Economics Center for Risk and Regulation, London, UK, May 23, 2019
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"Cyber Great Game: The US, the EU, Russia, China and Power Politics of Internet Security," and "Finance, Fraud, Cryptocurrencies and Next Frontiers in International Cooperation to Confront Cyber Crime," Aspen Institute Germany CyberSecurityForum, Berlin, Germany, May 16-17, 2019
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"Are We Sufficiently Decentralized Yet? A Look at US Token Taxonomy," 2019 Consensus Conference, New York, NY, May 13, 2019
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"Borderless—Law and Order in a Decentralized World," and "Race to Regulate: Who Will Build the Winning Paradigm," Global Blockchain Business Council's Blockchain Central, Davos, Switzerland, January 22-23, 2019
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Moderator, "Blockchain Technology: Detecting and Solving Cybercrime," HoshoCon Blockchain Security Conference, Las Vegas, NV, October 10, 2018
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"Without Borders, Who Rules? Arbitration and Legal Recourse in a Decentralized World," Blockchain Central at the 2018 Concordia Summit, New York, NY, September 24, 2018
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Moderator, "Best Practices for Tax Treatment of Digital Currencies," Accounting Blockchain Coalition Blockchain, Accounting, Audit & Tax Conference, New York, NY, May 17, 2018
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"Blockchain and Supply Chain: Navigating the Choppy Legal Waters," Consensus 2018, New York, NY, May 15, 2018
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"The Four Regulatory Lenses of Cryptocurrency and Crypto-Tokens," Policy Committee, Association of Bermuda Insurers and Reinsurers, Bermuda, March 13, 2018
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Moderator, "The New Barons of Cyberspace: ICO Creators and Ransomware Authors," SXSW, Austin, TX, March 9, 2018
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Moderator, "Keeping Track: Blockchain & Identity," Global Blockchain Business Council's Blockchain Central, Davos, Switzerland, January 26, 2018
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Moderator, "Securing Our Common Future in Cyberspace," World Economic Forum Annual Meeting, Davos, Switzerland, January 23-25, 2018
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Moderator, Senate Republican High-Tech Task Force Briefing: Blockchain 101, Washington, DC, November 8, 2017
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"Blockchain, Anti-Money Laundering, and Compliance," The Association of Banks in Singapore (ABS), Singapore, July 5, 2017
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"Public Private Cooperation: Blockchain and the Blockchain Alliance," Ontario Securities Commission Enforcement Conference, Ontario, Canada, May 31, 2017
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Moderator, "Fighting Cybercrime Using the Blockchain," RSA Conference 2017, San Francisco, CA, February 17, 2017
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"Emerging Technologies—A Double-Edged Sword," World Economic Forum Annual Meeting 2017, Davos, Switzerland, January 17-20, 2017
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Participant, Informal Gathering of World Economic Leaders on Agile Governance for the Fourth Industrial Revolution, World Economic Forum Annual Meeting 2017, Davos, Switzerland, January 17-20, 2017
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"Balancing Blockchain Public Policy: Thoughtful Regulation Without Stifling Innovation," Money20/20, Las Vegas, NV, October 23, 2016
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"The Blockchain Alliance," Europol 3rd Annual Virtual Currency Conference, The Hague, Netherlands, July 14, 2016
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Moderator, "The Hacked World Order" (interview with author Adam Segal), Aspen Ideas Festival. July 1, 2016
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"Blockchain and Security," Second Annual Blockchain Summit, Necker Island, British Virgin Islands, June 6, 2016
News & Publications
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
Press Releases
Steptoe’s Blockchain and Cryptocurrency Practice Recognized in Chambers FinTech 2024 Guide
December 18, 2023
Client Alerts
Proposed Rule Subjects Digital Payments to CFPB Oversight
November 14, 2023
By: Alan Cohn, Andrew Owens, Coy Garrison, Evan T. Abrams, Sophia Breggia, Vito Arethusa
StepTechToe
Courts Pump Brakes on Privacy Rights; California AG Responds with Investigative Sweep
July 21, 2023
By: Tod Cohen, Alan Cohn, Anne-Gabrielle Haie, Sonja Arndt-Johnson
Publications
Blockchain in the USA: 2022-2023 Developments
Chambers Global Practice Guides Blockchain 2023
July 6, 2023
By: Alan Cohn, Jason M. Weinstein, Coy Garrison, Shawn P. Davisson, Galen Kast, Sophia Breggia
Press Releases
Steptoe’s Blockchain and Cryptocurrency Practice Recognized in Chambers Fintech 2023 Ranking
December 2, 2022
Steptoe Blockchain Blog
FTX: An Explainer on What Happened and What’s Next?
November 29, 2022
By: Alan Cohn, Jason M. Weinstein, Coy Garrison, Sophia Breggia
Resources
Financial Services Group Advisory
Previewing Gary Gensler's SEC Confirmation Hearing
March 1, 2021
By: Alan Cohn, John T. Collins, Christopher R. Conte, Scott D. Fisher, Micah S. Green, Scott A. Sinder
Client Alerts
Significant FinCEN Action Against BTC-e, Implications for Virtual Currency Exchangers
July 31, 2017
By: Jack R. Hayes, Edward J. Krauland, Jason M. Weinstein, Alan Cohn
Events
Webinars
Post-Election Recap: Appropriations and Defense
December 2, 2020
Speakers: Leslie A. Belcher, Alan Cohn
Webinars
Post-Election Recap: Financial Services
November 12, 2020
Speakers: Alan Cohn, John T. Collins, Micah S. Green
Seminars & Events
March 1, 2018
Speakers: Jason M. Weinstein, Lisa M. Zarlenga, Alan Cohn, John Cobb
Harvard Club of New York City
35 West 44th Street
New York, NY 10036
Seminars & Events
Blockchain and Virtual Currency: Tax Issues Workshop
September 12, 2017
Speakers: John Cobb, Alan Cohn, Aaron P. Nocjar, Jason M. Weinstein, Lisa M. Zarlenga
Steptoe
1330 Connecticut Avenue, NW
Washington, DC 20036
Webinars
Don't Get Blocked by the Blockchain Webinar
October 22, 2015
Speakers: Alan Cohn, Jason M. Weinstein
Noteworthy
- Chambers FinTech USA, Blockchain and Cryptocurrencies (2019-2024)
- Legal 500 US, Next Generation Lawyer: Media, Technology & Telecoms: Cyber Law, including Data Protection and Privacy (2017-2019)
- Legal 500 US, Media, Technology & Telecoms: Cyber Law, including Data Protection and Privacy (2017, 2019)
- Legal 500 US, Media, Technology & Telecoms: Telecoms & Broadcast, Regulatory (2016)
- Legal 500 US, Media, Technology & Telecoms: Telecoms & Broadcast, Transactional (2016)
- Who's Who Legal, Fintech & Blockchain – Blockchain (2023)
- Law360, Fintech "MVP" (2019)
- National Law Journal, "Trailblazers in Cryptocurrency, Blockchain & FinTech" (2018)
- National Law Journal, "Trailblazers in Cybersecurity" (2017)
Professional Affiliations
- Co-Chair, Global Future Council on Cybersecurity (2016-2018) and Member, Cybercrime Experts Network, World Economic Forum
- Adjunct Professor, Georgetown University Law Center; Fellow, Georgetown Law Center on National Security and the Law; and Advisory Board Member, Georgetown Cyber Security Law Institute