Jason Weinstein and Alan Cohn are attorneys at Steptoe Johnson LLP in Washington DC, and counsels to the Blockchain Alliance.
Jason previously served as deputy assistant attorney general at the Department of Justice and serves on the advisory boards of BitFury, the Chamber of Digital Commerce and Coin Center. Alan served as assistant secretary for strategy, planning, analysis and risk at the Department of Homeland Security.
After an eventful 2015 for bitcoin and the blockchain, what’s in store on the regulatory and enforcement front in 2016?
Here are some things to watch:
1. Policing of onramps and offramps
With multiple federal regulatory agencies having outlined their mandates in the bitcoin and blockchain space and laid down how they intend to treat digital currencies, we are increasingly likely to see ‘regulation by enforcement’ next year.
That is, we may see more enforcement actions brought against particular industry companies, sending a message to other firms about how agency rules will be applied in practice.
The obvious focus of enforcement will be money service businesses (MSBs), which sit at the intersection between bitcoin and other digital currencies and fiat currencies.
While up to now some of these cases have involved ‘low-hanging fruit’