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 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.
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.
News & Publications
Press Releases
Steptoe Practices and Attorneys Earn High Rankings in the Legal 500 United States 2025
June 11, 2025
Blockchain Blog
DOJ Trims Charges in Tornado Cash Case
May 19, 2025
By: Evan T. Abrams, Andrew C. Adams, Galen Kast, Sophia Breggia, Nathaniel Sans
Blockchain Blog
OCC Confirms Banks May Provide Crypto Custody and Execution Services for Customers
May 8, 2025
Blockchain Blog
Federal Reserve Board Withdraws Guidance Regarding Digital Asset Activities
April 30, 2025
Blockchain Blog
SEC Articulates Standards for Non-Security Stablecoin, Providing Clarity for Issuers
April 15, 2025
Blockchain Blog
Deputy Attorney General Memorandum: "Ending Regulation by Prosecution"
April 11, 2025
By: Marlon Paz, Andrew C. Adams, Evan T. Abrams, Galen Kast, Ryan Hayden, Sophia Breggia
Press Releases
April 9, 2025
Events
Webinars
An Insider's Perspective on DOJ with Andrew Adams
November 8, 2023
Speaker: Andrew C. Adams
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, Ali Burney, Henry Cao, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, Grace Wang, Philip R. West, Charles Whiddington, Wendy Wysong, Lin Yang, Bo Yue, Wilson Zhao
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
Resources
Focus on Tax Controversy Newsletter
IRS Revises Voluntary Disclosure Form with Expanded Cryptocurrency Section
March 2022
By: Caitlin R. Tharp
Financial Services Group Advisory
Previewing Gary Gensler's SEC Confirmation Hearing
March 1, 2021
By: Alan Cohn, Christopher R. Conte, Scott D. Fisher, Micah S. Green, Scott A. Sinder
Exempt Organizations Advisory
December 29, 2020
Client Alerts
President Imposes First US Economic Sanctions Against Venezuelan Digital Currency
March 26, 2018
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