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- Blockchain Technology
Distributed ledger technologies, including blockchain, will undoubtedly have a significant impact on the way companies in all sectors, and many governments operate. As with any disruptive technology, blockchain presents tremendous opportunities but may also raise legal, regulatory, and business challenges.
Covington has broad-based experience across the many industries in which this technology will be deployed. The firm is uniquely positioned to advise clients in connection with policy, regulatory, litigation, enforcement and investigations, privacy and data security, consumer protection, and transactional matters relating to distributed ledger technology.
Our team includes more than 120 former government and enforcement officials, including the former U.S. Attorney, a former Prime Minister, and a member of the UK House of Lords, who can offer our clients exceptional insight as they navigate complex regulatory, legal, policy, and litigation issues relating to the adoption of disruptive technologies. We provide comprehensive, interdisciplinary advice to clients looking to acquire, adopt, evaluate, or litigate matters relating to distributed ledger technology.
Covington advises clients of all sizes in connection with a broad array of legal and business matters at the cross-section of technology innovation and regulation, including blockchain, in relation to:
- Global, federal, and state regulatory frameworks
- Financial services regulatory enforcement and investigations, including Anti-Money Laundering advice
- Insurance coverage and disputes
- Data privacy and cybersecurity
- Commercial litigation
- Public policy and government affairs
- Technology transactions
- Mergers and acquisitions
- Venture capital and private investments
- Capital markets and securities
- Futures and derivatives regulation
- Tax
Blockchain Asset Acquisition
Advising a financial services company in connection with its acquisition of blockchain assets.
Blockchain Industry Association
Providing strategic advice and support to a new blockchain industry association.
Bitcoin Regulatory Advice
We analyzed CFTC regulatory issues on behalf of digital currency wallet and platform provider, including the launch of an exchange and meetings with the CFTC Chairman, Commissioners, and staff to discuss the company and its request for no-action relief.
Blockchain Public Policy Counsel
We provide regular government affairs and public policy support and advice to a blockchain infrastructure and transaction processing company. In particular, we help them identify key stakeholders for Blockchain issues and guide them in their discussions with regulators in various jurisdictions and various industry sectors.
Corporate Counsel to Blockchain Startup
Advising a start-up blockchain company building an identity platform in connection with corporate, venture capital, privacy, and commercial licensing transactions.
Bitcoin Technology in Transfer of Currency from Currency-Controlled Jurisdiction
A multinational company regarding a transaction to use Bitcoin and related blockchain technologies to transfer currency from a currency-controlled jurisdiction to the United States and European Union.
Blockchain Technology Advice
Advising a Fortune 100 company in connection with its evaluation of a blockchain-based technology service for cross-border payments.
Whitepaper on Cybersecurity Advantages of Blockchain Technologies
Advising Microsoft and the Chamber of Digital Commerce in the development of a whitepaper exploring the cybersecurity advantages of blockchain technologies.
November 16, 2020
WASHINGTON—Global Banking Regulation Review has named Covington partner Michael Nonaka to its “45 Under 45,” a list of the leading, next-generation banking regulation specialists. Mr. Nonaka is co-chair of the Financial Services Group and advises banks, financial services providers, and non-bank companies on a broad range of compliance, enforcement, ...
July 23, 2020, Global Policy Watch
Today, the OCC released an interpretive letter concluding that national banks and federal savings associations (together, “banks”) may permissibly provide cryptocurrency custody services for customers. The letter, written by Chief Counsel Jonathan Gould, describes custody of cryptocurrency as a modern form of the traditional banking activity of providing ...
July 22, 2020, Cov Financial Services
Today, the OCC released an interpretive letter concluding that national banks and federal savings associations (together, “banks”) may permissibly provide cryptocurrency custody services for customers. The letter, written by Chief Counsel Jonathan Gould, describes custody of cryptocurrency as a modern form of the traditional banking activity of providing ...
February 14, 2020, Cov Financial Services
On February 12, 2020, the Board of the International Organization of Securities Commissions (“IOSCO”) released a report titled Issues, Risks and Regulatory Considerations Relating to Crypto-Asset Trading Platforms. The report describes the risks associated with crypto-asset trading platforms (“CTPs”) and sets forth key considerations for regulators in ...
November 26, 2019, Global Policy Watch
Shift to a services era While Africa’s trajectory remains full of daunting challenges, there is reason to be optimistic. Ratification of the Continental Free Trade Agreement demonstrates critical collaboration between African leaders, and promises to unlock the region’s potential. Equally important, growing investments in broadband ensure that affordable access ...
October 14, 2019, Cov Financial Services
On Friday, the leaders of the Securities and Exchange Commission (“SEC”), Commodity Futures Trading Commission (“CFTC”), and Financial Crimes Enforcement Network (“FinCEN”) (collectively, the “Agencies”) issued a “Joint Statement on Activities Involving Digital Assets” (the “Joint Statement”). The Joint Statement serves as a reminder that businesses engaged in ...
Exchange Rules Spark Conflict
August 14, 2019, The Information
Anne Termine spoke with The Information about the issues cryptocurrency exchange companies face with U.S. regulation. Some exchange companies have resulted to forbidding U.S. customers from using their services. Ms. Termine said that to avoid regulatory scrutiny and possible fines, crypto exchanges should make a “reasonable effort” to prevent U.S. residents from ...
August 4, 2019, CoinTelegraph
Michael Nonaka spoke with CoinTelegraph to discuss cryptocurrency regulation in the U.S. Mr. Nonaka says, "The U.S. Financial Crimes Enforcement Network issued its first guidance addressing cryptocurrency companies in 2013, and since then regulatory action for digital assets has been slow to develop but has picked up in the past few years as an increasing ...
July 29, 2019, Global Policy Watch
On July 23, the New York State Department of Financial Services (“DFS”) announced a new Research and Innovation Division. The Division will assume responsibility for licensing and supervising virtual currencies. It will also “assess efforts to use technology to address financial exclusion; identify and protect consumer data rights; and encourage innovations in ...
July 29, 2019, Cov Financial Services
On July 23, the New York State Department of Financial Services (“DFS”) announced a new Research and Innovation Division. The Division will assume responsibility for licensing and supervising virtual currencies. It will also “assess efforts to use technology to address financial exclusion; identify and protect consumer data rights; and encourage innovations in ...
Prominent Financial Services Lawyer Joining Covington
July 1, 2019
WASHINGTON—Jeremy Newell has joined Covington's Financial Services Group as a partner in Washington. Mr. Newell's arrival follows the recent addition of Karen Solomon, who joined Covington after serving as the acting Chief Counsel of the Office of the Comptroller of the Currency. Mr. Newell was formerly Executive Vice President, General Counsel & Chief ...
June 21, 2019, The Wall Street Journal
Michael Nonaka is quoted in The Wall Street Journal regarding the Financial Act Task Force’s request to virtual currency firms to develop procedures for sharing customer information with other financial institutions. Mr. Nonaka says that some crypto companies have invested heavily in compliance, others have a long way to go to build the systems necessary for ...
Feds Send Clear Message With Flurry Of Fintech Cases
June 7, 2019, Law360
Anne Termine is quoted in Law360 regarding the SEC’s enforcement on fintech and cryptocurrency matters. Ms. Termine says, “From my perspective, having a no-fine case is a pretty big deal. And I think the SEC wanted to make pretty clear that it was a big deal that this was a self-report and that [the company was] recognizing the SEC jurisdiction, that they were ...
CNBC Europe - U.K. National
May 7, 2019, CNBC
Francis Maude appeared on CNBC to speak about Brexit’s effect on British markets and the upcoming election.
March 28, 2019
BRUSSELS—Sebastian Vos, partner and co-chair of Covington’s Public Policy Practice, has been named co-chair of the Global Blockchain Business Council’s Legal and Regulatory Working Group. The Global Blockchain Business Council (GBBC) is the leading trade association for the blockchain technology ecosystem and brings together innovative organizations and thought ...
January 31, 2019, Cov Financial Services
Innovation in financial services continues to move at a rapid pace. The significant increase in the number of fintech companies in recent years has highlighted a burgeoning market with significant economic potential, and a commercial need to create efficiencies and modernize the provision of financial products and services. Federal and state financial services ...
January 22, 2019, Cov Financial Services
New York has enacted the Digital Currency Study Bill, which will establish a digital currency task force and provide the governor and the state legislature information “on the effects of the widespread use of cryptocurrencies and other forms of digital currencies and their ancillary systems in the state.” The task force will conduct an extensive...… Continue ...
Crypto Exchanges Left Hanging as Shutdown Sidelines CFTC
January 15, 2019, Bloomberg Law
Anne Termine is quoted in Bloomberg Law regarding the Commodity Futures Trading Commission’s enforcement of cryptocurrency coming to a halt with the government shutdown. Ms. Termine says, “It’s an agency working at 10,000 feet right now.” She adds that an extended shutdown could impact the agency’s preparation for oral arguments. “In litigation, March is around ...
December 5, 2018, Cov Financial Services
FinTech and blockchain technologies are rapidly developing. With the emergence of so many new ideas and technologies comes the need for action, to protect both current and future innovations. Given the pace at which technology continues to disrupt the industry, securing IP assets—especially patents—should be a primary consideration for companies in this space. ...
December 1, 2018, Cov Financial Services
The CFTC’s LabCFTC recently released “A Primer on Smart Contracts” as part of LabCFTC’s initiative to engage with stakeholders on FinTech topics. The primer explains smart contracts, and explores their potential benefits — with a particular focus on the financial sector — and challenges. The CFTC has an interest in smart contracts because, as the...… Continue ...
December 2018, Covington Alert
FinTech refers to the use of new and emerging technologies in the financial services industry to improve the delivery of financial services to customers, and includes innovations such as cryptocurrencies and open banking. Recent years have ushered in the use of several key technologies in the FinTech landscape, including artificial intelligence, data analytics, ...
December 1, 2018, Practical Law
This chapter provides a comprehensive overview on fintech regulation in the United States as part of a global fintech guide published by Thomson Reuters. Reproduced from Practical Law with the permission of the publishers. For further information, visit www.practicallaw.com.
November 30, 2018, Global Data Review
Trisha Anderson is quoted in Global Data Review regarding cyber and ransomware attacks. Ms. Anderson said that while the use of technologies like Tor and Bitcoin pose challenges to law enforcement by “raising the level of investigative effort and sophistication required to identify and locate cyber criminals,” the indictment in the SamSam Ransomware cyberattacks ...
September 28, 2018
WASHINGTON—The National Law Journal has named Covington's Michael Nonaka to its inaugural list of "Cryptocurrency, Blockchain, & Fintech Trailblazers." This list profiles 50 lawyers who have "moved the needle" and are making great strides as finance and technology grow more entwined. Mr. Nonaka is co-chair of the firm’s Financial Services Group and advises ...
July 25, 2018, Global Policy Watch
Blockchain technology has the potential to revolutionise many industries; it has been said that “blockchain will do to the financial system what the internet did to media”. Its most famous use is its role as the architecture of the cryptocurrency Bitcoin, however it has many other potential uses in the financial sector, for instance in...… Continue Reading
July 24, 2018, Cov Financial Services
Blockchain technology has the potential to revolutionise many industries; it has been said that “blockchain will do to the financial system what the internet did to media”. Its most famous use is its role as the architecture of the cryptocurrency Bitcoin, however it has many other potential uses in the financial sector, for instance in...… Continue Reading
July 17, 2018, Cov Financial Services
On July 16, 2018, the Financial Stability Board (“FSB”) issued a report to the G20 Ministers of Finance and Central Bank Governors summarizing the work that the FSB and other international standard-setting bodies have undertaken regarding crypto-assets. The FSB notably reported that it has developed a framework for monitoring financial stability risks related ...
Law Firms Hitch a Ride on the Blockchain Wagon
April 3, 2018, Washington Lawyer
Michael Nonaka is quoted in a Washington Lawyer article regarding legal opportunities surrounding blockchain. While some lawyers might eventually become blockchain-specialty attorneys, blockchain is looking “more like a technology you have to know about if you’re in certain industries,” says Nonaka. For instance, highly regulated industries such as energy and ...
March 9, 2018, Cov Africa
When bitcoin entered the public’s eye for the first time in 2013, it was touted as one of the greatest inventions for the unbanked in Africa. The World Bank estimates that of the 2 billion people without access to the modern financial system, a third live in Sub-Saharan Africa. In recent months, bitcoin and cryptocurrency...… Continue Reading
January 31, 2018, Global Policy Watch
The European Commission (“EC”) has stated that the almost limitless list of potential use cases of distributed ledger technology (“DLT”) makes it both very promising and challenging, and has expressed its support for blockchain and DLT.[1] However, many European institutions are still of the opinion that the technology is at its early stage of development,...… ...
Fintech Startup, Covington To Launch Blockchain Council
January 6, 2017, Law360
Sebastian Vos is quoted in a Law360 article regarding the launch of a Global Blockchain Business Council at this year’s World Economic Forum by Covington and The Bitfury Group. “Blockchain has the potential to be the next great technological innovation, revolutionizing areas from cross-border payments, trade finance and land registries to government records,” ...
- Law360, Banking Group of the Year (2018)
- US News/Best Lawyers, Law Firm of the Year – Financial Services Regulation Law (2016)
- Chambers USA, Financial Services Regulation (2016)
- Chambers UK, Financial Services: Non-Contentious Regulatory (2015)
- Chambers Global, Banking and Finance: Regulatory (2016)
- Chambers USA, Securities: Regulation (2016)
- Legal 500 US, Financial Services: Regulatory and Litigation (2016)

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