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Home / Resources / TRM Talks / Every Lawyer Is a Technology Lawyer Now: Lewis Rinaudo Cohen on Machine Law

Nov 4, 2026 - 39min

EPISODE 123

Every Lawyer Is a Technology Lawyer Now: Lewis Rinaudo Cohen on Machine Law

With Lewis Rinaudo Cohen,  and ,  and  and

Lewis Cohen, Co-Head of Cahill Next at Cahill Gordon & Reindel, joins Ari Redbord, TRM Labs' Global Head of Policy, to explain why he calls his practice "machine law," not AI law. It's about the legal questions that arise when autonomous agents, not humans, execute financial transactions at scale.

Ari and Lewis talk about his path from structured and Islamic finance to founding a crypto boutique in 2018 and building Cahill Next with partner Samson Enzer. Why every lawyer is now a technology lawyer. And why conviction, not credentials, separates the lawyers who thrive from those left behind.

They also get into tokenization and a question the industry is wrestling with. As adoption grows, is it moving us away from the promise of decentralization? Lewis argues a credibly neutral network like Ethereum or Solana is what lets institutional tokenization cross borders, something no government-run system can do alone. Plus the SEC's new innovation exemption for automated market makers, the fallout from the Clarity Act, and how the century-old logic of Howey still guides lawyers working on technology with no precedent.

Listen to the full episode, Every Lawyer Is a Technology Lawyer Now: Lewis Rinaudo Cohen on Machine Law. Follow TRM Talks on Spotify to be the first to know about new episodes.

Ari Redbord (00:02):

I'm Ari Redbord, and this is TRM Talks. I'm Global Head of Policy at TRM Labs. TRM is an AI investigations and threat intelligence company combining on-chain and off-chain data to combat modern crime and build a safer world. We use our AI investigations platform,  Ardence, along with Chainabuse and the Beacon Network to bring together the public and private sectors to defeat scam networks, ransomware gangs, terrorist financiers, and other threats. Prior to joining TRM, I spent 15 years in the US federal government, first as a prosecutor at the Department of Justice and then as a US Treasury Department official, where I worked to safeguard the financial system against terrorist financiers, weapons of mass destruction proliferators, drug kingpins, and other rogue actors. On TRM Talks, I sit down with business leaders, policymakers, investigators, and friends from across the blockchain, AI, and technology space who are working to build a safer world.

(01:13):

On today's TRM Talks, I sit down with OG crypto lawyer and Cahill Next practice leader Lewis Cohen. But first, Inside the Lab, where I share data-driven insights from our blockchain intelligence team.

(01:31):

On today's Inside the Lab, a Europol-led operation took down a laundering service that processed 336 million euros for ransomware gangs, and TRM had already identified it as a target months before the takedown. AudiA6 was tied to more than 15 cybercrime investigations, including the 2022 LastPass breach. US prosecutors charged two operators, both arrested in Georgia. Roughly 80% of AudiA6's traced illicit exposure tied directly to ransomware. That fits a broader pattern. The top five off-ramp services absorb 42% to 57% of all ransomware volume every year. A small number of services handle most of the laundering, which is what makes them worth targeting. TRM had flagged AudiA6 independently in December 2025 after de-mixing LastPass-related funds and tracing them to the service. The broader picture is improving on payments even as laundering evolves. Global ransomware payments fell to about $1.3 billion in 2025, down from $1.9 billion, even as victim postings rose 44%, meaning attacks are increasing while fewer victims pay. Mixer volume has collapsed, while cross-chain bridge volume overtook mixers as the preferred laundering method for the first time in 2025. One AudiA6 operator, asked if drug proceeds were acceptable, replied bluntly, "Everything like that needs to go through a mixer." Proof these services position themselves as dedicated criminal infrastructure.

(03:14):

And now my friend Lewis Cohen.

(03:19):

Today, I am joined by a very special guest, an extraordinary friend, really a trailblazer in the technology, crypto, blockchain, legal space, Lewis Cohen. Lewis, I've wanted to do this with you forever. I recall this, and you may not, because you have these types of conversations, I'm sure, with people all the time. But I want to say it was close to five years ago. We were at a conference summit at Penn, and I believe, after maybe a dinner or something, we ended up at the bar, just the two of us.

Lewis Rinaudo Cohen (03:44):

I remember well.

Ari Redbord (03:45):

An hour or more, we had conversations around privacy and technology and the stuff that we do from a blockchain intelligence perspective, and how that conflicts or doesn't conflict with the privacy space. And I almost felt like we had a TRM Talks that day, and I've been wanting to have it publicly ever since. So thank you for doing this.

Lewis Rinaudo Cohen (04:05):

I'm thrilled. Thank you.

Ari Redbord (04:07):

Talk to me about your journey into the crypto lawyer world.

Lewis Rinaudo Cohen (04:11):

Ari, it's such a fascinating thing. I frequently talk to lawyers starting out their careers and ask often about the same thing. I think the most important word when I reflect is conviction, and I think for lawyers entering a very changeable market, that word becomes only more important. My journey was all about what did I enjoy, what did I like, and what did I believe in? What did I have conviction about? I started out my career gravitating quite quickly into the world of structured finance, which was a new thing at that time. I just found it intellectually interesting. When I was a kid, I used to make up a lot of games. I had time on my hands, and I found that structured finance was something that I just found pleasure in. As my career progressed, I looked for ways to apply those skills. And over many years, when I discovered ultimately the ideas behind underlying blockchain, underlying Bitcoin, underlying Ethereum, I said, "Oh my goodness, this is really where this was all headed." And so I kind of fell into it, but because I followed my conviction, what I wanted to do, what I enjoyed doing.

Ari Redbord (05:22):

And what is so cool is obviously you identified this technology as something that you are passionate about and wanted to work on. Was there a specific moment when you had that kind of aha around Bitcoin or Ethereum, or the technology?

Lewis Rinaudo Cohen (05:35):

Yeah. In my case, Ari, it was less. For many people, it was the kind of financial independence part, and particularly Bitcoin for people early on, that brought them into the space, and that's obviously exciting and important. In my case, it was a little different. It was more the structure and function of particularly the Ethereum network and being able to code deterministic smart contracts that basically do what I had been doing for many, many years with pen and paper, but in a wholly automated way. And the idea of automation, I think, is quite important. But that idea and concept became just absolutely fascinating to me, along with the idea that value, and this is if I learned one thing from crypto, it's that value is data that is subject to compute in a decentralized way. And I think that concept, I said, "Oh my goodness, this is gonna be a big thing." And even in the earliest of early days, when I was at a different firm at the time, and I went to our managing partner, and everybody just wanted to pat me on the head. "Nice, nice. You go enjoy your little thing. What's that got to do with me?" And I think it has everything to do with anyone who works in anything to do with the movement of value around the world. And so that's really what, for me, pulled me in then, rather than more of an internal, "Wow, I can control my own money. I could put Bitcoin on a Ledger wallet and take it." And that's a hugely important and valuable thing. But for me, it was this automation of value in a deterministic way around the world.

Ari Redbord (07:07):

It is so cool, and it is fun to hear that origin story, because so many people do have a sort of different one. I mean, for me, it was like very early, well, bad guys are using this, but we can also use technology to stop them. So you built a boutique that just focuses on technology. Talk me through a little bit about that moment in your career.

Lewis Rinaudo Cohen (07:25):

Absolutely, Ari. And it really ties into this idea of conviction. And I think, firstly, you have to have the support of your family and your loved ones. Firstly, I did talk to my wife, made sure she didn't think I was absolutely insane to leave a partnership at a very large firm and start a boutique, and she didn't, thankfully. And I really said, "Look, if you're going to do something," I've always been a believer, Ari, that you have to go all in on things. Oddly enough for a guy whose last name is Cohen, I did Islamic finance for about five years. And when I did that, I studied Arabic. I said, "Look, if you're gonna do that, I wanna understand the source text, and I wanna be able to fully engage with it." And it was a similar sort of thing when I said, "I think this, the idea of crypto assets moving through blockchain technology, is an important concept." I really wanted to understand it down to the basics, and I knew that I was not gonna be able to do that at that time, which was quite early on in the large firm context. And so the way to do that really was on my own. I said, "Look, I have conviction. I believe this is gonna be a thing." I started that firm back in, I guess, 2018, I think. And it was quite early, and it all worked out, so it was just great.

Ari Redbord (08:35):

It's extraordinary. And then obviously, eight, 10 years later, you make the jump to a larger law firm. You're now at Cahill. You've built the Next practice there. Would you talk to me a little bit about what that means, Cahill Next? And then just that jump maybe back to more big law life?

Lewis Rinaudo Cohen (08:53):

Well, Ari, I'm sure you go on the internet, you can find plenty of places where it's, "I'm never going back. Forget about it. God, that pulled me back in." I really enjoyed the ups and downs of being in total self-control of, like, I hope that client pays so I can make my car payment or whatever the heck. But ultimately, the large firm lawyer inside me was always there. It never really went away. And what I saw was the world kind of coming more towards where I was, that the traditional financial institutions were starting to understand how important this was, and at a boutique firm, it was just going to be difficult. I think I would've nevertheless toughened it out, but I was very, very fortunate to meet the co-head of Cahill Next and my partner and founder, Samson Enzer. And Sam and I very quickly hit it off. Very different, yin-yang. I'm a Capricorn, he's a Sagittarius. My wife likes to point that out. She's a Sagittarius, I'm a Capricorn. We got this kind of yin-yang sort of energy. But we shared a vision, and that vision was that this was going to be incredibly important and that a place like Cahill was the exact right place to do it. Unlike some other firms that had disparate practices, and look, these are great firms, but they had a pocket here, a pocket there, a pocket somewhere else. Cahill was just getting started. Sam had joined the firm a year and a half or so previously. What Cahill presented was an opportunity that almost no other place would present, and that was a clean piece of paper to build the kind of practice we both believed in, an integrated practice where transactional lawyers and litigators would work in close cooperation. Sam, as a litigator, works frequently on transactional or regulatory matters, and I work frequently with Sam and our litigators on those. That's really hard to build in an existing firm infrastructure. So what Cahill Next really allowed us to do was create the practice that we believed would best serve the market. I am so grateful. At the time I joined, Cahill was not ranked at all in the major firm rankings, Chambers and Partners, and here we are two and a half years later, we're in band one, and I feel very grateful. And that was very much of a team effort, that no one person can do that. That is because we surrounded ourselves with the very best colleagues, friends, and ultimately partners and lawyers. And that's what this really was about, is serving clients to the best of our ability.

Ari Redbord (11:18):

Amazing. Before we jumped on, my colleague Wesley, who produces TRM Talks, had this great question, and I'm just gonna ask it 'cause it was so good. And that is, what does Cahill Next mean? It's so interesting that you have added that brand to the bigger Cahill brand. Talk me through that.

Lewis Rinaudo Cohen (11:34):

Well, Ari, there were so many good things about leaving big law and having a boutique practice, and among them is the art of the possible. And because we served so many frontier clients, we felt instinctively they would understand what we're trying to say here. Now, what does that mean exactly? Obviously, a predominant part of our practice has always been and always will be blockchain-related work, crypto asset-related work, stablecoins, tokenization, all of these things. But from the very start, it was more than that. It was new technologies and how they're impacting us, artificial intelligence, agentic activity, et cetera, so those are all part of it. So it's really for us, Cahill Next is the place where we bring frontier legal knowledge and thinking to frontier issues in technology and finance.

Ari Redbord (12:25):

You know what's so interesting? It's such a cool answer, and it's one thing I get a lot, and you do too, is young lawyers, law students asking, "How did you build what you built?" And I think in the branding answer, it speaks a lot to that, and it's like, who says you can't do that, right? Push through those boundaries. I've had more fun doing that in the last six years at TRM than I've had at any time in my career, because it's like the answer is always, "Well, why can't you when you're seven people?" We're 500 today, and it's, I think in large part, because we keep saying, "Hey, well, why can't you just do that thing?" I think you honestly got into it a little bit, so why don't I just kind of stick with it. We are in an AI moment. I don't know that we've ever seen technology move faster than this has been moving. It opens up a host of legal, regulatory, litigation, compliance, liability-type issues. Talk me through how Cahill Next, how you personally, are kind of thinking about this agentic moment.

Lewis Rinaudo Cohen (13:28):

It was very clear to me early on this was going to be an absolutely essential technology, not just for a consumer who wants to use a shopping bot to go and find the cheapest pair of sneakers. Because it's all the same thing when you think about the consumer finding the cheapest pair of sneakers and a hedge fund manager trying to find the best source of liquidity. These are all in a continuum, and it's very much of that. That's what it means. And it felt like when I did a survey of what other law firms were doing out there, nobody was really speaking to this in a cohesive way. And I said to Sam, who was fully on board, I said, "This is the place for Cahill Next. This is the place where we pull together all these strands, the disputes that will inevitably arise, the regulatory questions that as crypto lawyers we're very comfortable with, this uncertainty and gray area, and the cutting-edge drafting and helping our clients navigate." So this was really, for me, the next step. Now, where this all leads to, so hard to say, but it was very clear this is where things are going, and you can't not be here.

Ari Redbord (14:30):

If I'm thinking through who are the clients that are walking in your office today, and what are the issues that you're maybe seeing most frequently, or the ones that are most interesting, or the ones that you think will be most important?

Lewis Rinaudo Cohen (14:41):

Well, a couple of starting points. There are platforms that are now being accessed by users, agents. And we published something on this aspect on the DeFi side. People are not really preparing their terms of service for agentic contact, what it means, who's allocating responsibility. So the very first entry point has been helping clients think that through. And to do that, you really need to understand what does it even mean to be an agent? How do they work? How do we control all of these things? We've seen, I alluded to Amazon before, very famously, they told Meta that Muse bots were not welcome on their platform. I think that's going to be really not the trend forward. I think people are gonna want to welcome agentic activity, but we're gonna need to think about how that works. I see that area particularly with decentralized finance and open platforms that will allow any user, with a wallet, to interact with them. You don't know any user, and now also agents.

Ari Redbord (15:49):

I just think this is the most interesting thing, and again, not something I have spent a lot of time thinking about till recently. I wrote a piece for Forbes about how I used an agent to find Caitlin Ones, Caitlin Clark Ones when it came out on that Monday. And honestly, part of that for me is a learning journey. I just want to figure out how to do it. But Amazon is great. It's a walled garden today. It has its own AI function. But what's really more interesting is how do you do what you're describing, and that is how do you use your agent to go across the internet?

Lewis Rinaudo Cohen (16:23):

100%.

Ari Redbord (16:24):

I mean, there's so many interesting legal questions. I'm sorry to interrupt, but talk me through that, 'cause I think it is so interesting right now.

Lewis Rinaudo Cohen (16:32):

100%. And I would say it's very similar, Ari. It's very similar for myself and for some others in the legal crypto space. You gotta get a wallet. You gotta use MetaMask. You gotta start doing these things to understand both the legal issues and the practical issues around it. So for me, this is not any great accomplishment, and your more sophisticated people would laugh, but I just started building out a Slack channel for myself with my various agents in it, which turned out to be kind of a pain in the place you sit on. But I got in there on the damn command line and started doing it. But unless you start doing it and see, "Oh, I see how this works. I see how that works. I see the art of the possible." I would say at this point, the only thing really limiting us with AI at the moment is our own imaginations. I have not encountered something where I had an idea, "Huh, I wonder if you could do that," and the answer is, "Nope, nope, can't do that." Yes, you just have to think about it. So in terms of legal issues, to pull it back, what are the legal issues? The starting point really is, are agents of others encountering what you're doing? But very soon we had institutional-type clients asking, "Well, we're using agents too. What does that mean for us? How do we manage those guardrails?" So we published a piece which we call Machine Law, and we use that term really to seek to distinguish. I think AI law, it's just too big a category right now to have it make sense. But by machine law, what we mean is the law around transactions of scale that involve autonomous systems. And a lot of that has been, well, sure, yes, we're a fund. Yes, we're a financial institution. Yes, we're a liquidity provider. In many cases they've used machine learning in the past, and they've used deterministic software. Isn't it kind of the same thing? Well, it's not the same thing when you're using a third-party model that's probabilistic, and there's so many different things that happen in that chain. But you have to, to your point, Ari, you have to get under the hood and understand concepts like compaction. When you give information to an agent and it's doing multi-step transactions, ultimately that process gets compacted down and changed, and you may not even be aware of that. Now, you could have evaluations subsequently, but those depend themselves on other agents. Many people answer, "Well, we have a human in the loop. Don't worry, guys, human in the loop." I wonder, the people who say that, do you ever use AI, man? Well, I ask a question. We use in our law firm Harvey, a very popular legal harness service provider, and it's great. Fantastic. You ask a question like this, you get an answer like that. And so just digesting what the AI wants to tell you about is a huge transaction. When you start talking about financial transactions at that pace, it's just not realistic. And in our Machine Law article, there's a quote from Sarah Breeden of the Bank of England, when she says, "A human in the loop is just not a realistic regulatory answer." It's not gonna happen. There is too much happening too fast, and so we need to really think about this. So helping our clients work through those processes, where does the human in the loop apply? Where are the critical stop points? And of course, everybody's talked about the Hugging Face incident. We all understand that. But it's a much wider sort of issue. And so where we're getting tremendous demand now from clients is to help them think through and understand that before the systems get built. Engineers love running forward, and you let them, they'll just kind of do things. Legal has to have a critical place here because these are transactions of value, and they do change people's legal positions. And that's really where I think the Cahill Next practice is very focused. So at one point, for example, you might say you're an insurance company. At this point you say, "I'm a technology company in the insurance business." I would say you're not a technology lawyer. Your technology is the core of what you do, and you happen to use that in the context of the law. You're not escaping this. It's not going away. It is what you do. Everybody's a technology lawyer. And I think that message hasn't completely sunk in to everyone yet. And I think we see a lot of younger lawyers really worrying about, I mean, we see a lot of younger people who are not lawyers worrying about their careers and the future. Certainly younger lawyers, "Am I gonna be replaced?" My answer is, you won't be replaced at all if you engage now, you understand that, and you make yourself someone who can marshal these tools.

Ari Redbord (21:15):

Amazing. The other piece to this is, and you can bring in your sort of crypto lawyer hat as well. I mean, there is all so much connectivity here. But I think one thing that is a little intimidating about this space is that there are arguably no answers, right? Where does the line around liability lie? How do we sort of deal with this? I feel like you have been dealing with that in the crypto space for years, but I bet that you also have analogies. Talk me through how you think about answering these questions that are coming to you that are oftentimes, there is no case law, there is no legal precedent for, because you are truly inventing the wheel in many ways.

Lewis Rinaudo Cohen (21:53):

Ari, when we were prepping, I mentioned that I spent a not inconsiderable portion of my career in the world of Islamic finance. One of the things that is interesting about that is lawyers today still go back to the most basic of principles, sayings of the prophet, other statements, and extrapolating out to reach conclusions today. Many times, particularly my entry point was very much as a securities lawyer around the well-trodden Howey case involving the orange groves. We find ourselves still extrapolating and just having to use our judgment as to what is closest to the principles that we are trying to apply. It is the very same thing. You are absolutely right, there are no answers. Really, the not having answers is not a problem if you have principles. That is what I would say. If you are able to apply those principles, you will be able to guide your clients.

Ari Redbord (22:50):

Getting into the crypto stuff a little bit, and I think it's impossible to separate AI and crypto today. But I'd say one of the real focuses out there in the world within the digital asset space is this moment for traditional financial institutions getting involved, and obviously tokenization is such a huge piece of that. I feel like that just sits so perfectly in your wheelhouse as someone who has thought about these issues for a long time. Would you talk to me a little bit about the tokenization moment and where you think we're headed with this?

Lewis Rinaudo Cohen (23:18):

One thing that has gotten a little bit lost in the dialogue is the critical concept of decentralization. I think it sort of faded away. The Blockchain Regulatory Certainty Act, which was going to be part of the CLARITY Act ultimately, and of course was lost, was really trying to ensure that this was important. The crypto community has had a fraught relationship, I would say, with decentralization. It is essential. Without that, we just have simply software, which we've had forever, and that's wonderful, and we have a business, and we have lock-in, and we have equity investors. What crypto brought to the table was the idea that technology didn't have to be owned or controlled in the way it always had been. That opens up many concerns, and you and TRM Labs and so many others fight the good fight, because there are risks by having open technologies like this. But we have to fight the good fight. But it is hugely differentiated. And even if a relatively small percentage of the population wants to legitimately use these technologies, that is a critical piece. It's an escape valve. If you have a pressure cooker and the thing at the top that lets the steam out, it's maybe a small amount that's coming out, but it's critical. Tokenization, in the way I'll talk about it in a moment at the institutional scale, is only possible and relevant in the way we're thinking of it because of that. You cannot separate these two things, because what tokenization relies upon is a credibly neutral platform. And as long as we can maintain that, or something, I hope, that stays very close to that, which is primarily at this point the Ethereum network and the Solana network. There are some other networks that I think get close and deserve credit, but primarily that. That is really critical, because I think people talk about digitization. Securities have been digital, whatever exactly that means, electronic, whatever exactly that means, for 25, 30-plus years, electronic. But they were always in a controlled setting, a clearing system. For the most part, we had a paperwork crisis, as you probably are aware, Ari, with paper securities, and we moved to a digital system. But it was in a controlled and walled garden. What that meant is the US had our own system, Europe had its own system, Japan had its own system. These were clearing and settlement systems. What Ethereum and Solana and perhaps other networks do, and what tokenization does, is something that governments cannot do. It breaks down those walls. Europe is never going to say, "You know what, guys? You seem to do a great job over there in the US. I know it's all dollarized. I tell you what, just forget our thing. We'll just use your thing." Zero. No happening. And it is not happening in India, it is not happening in China, it is not happening in Japan or in Brazil. But you know what? It is happening with Ethereum. That is what everybody said. You know what? This is such a better means of transferring, trading, owning, and dealing, pledging, et cetera, with securities that we are going to all slowly but surely migrate to this separate non-national, non-jurisdictional system. And that all depends on that system being incredibly neutral and having decentralization. So I think when we talk about tokenization, the reason we want that is because it allows the financial system to escape those national boundaries. That only does that if we have this baseline. So I know it is a very long answer, but I think it is critical to understand how those pieces fit together.

Ari Redbord (27:02):

How do you feel about the tension, then, between these types of products? There are now funds. We can buy Bitcoin through a fund. Talk me through that tension for you.

Lewis Rinaudo Cohen (27:13):

You're absolutely right. And I think that tension comes, Ari, from the fact of the matter that people want and need convenience. And also, in complete fairness, for all the slings and arrows thrown at centralized systems, they work pretty well. Not a lot of people, and that's because of a lot of hard work by many people who are not paid very well, who are in government service, who do a lot of things to keep that whole system up and running. And that does create tension. I think the key thing, though, is coming back to this idea of the escape valve. The fact that you can, when you want to, if you need to, take your value out of that system. Previously, we had that, right? It was called paper money. That was so hopelessly inefficient.

Ari Redbord (28:03):

You really uniquely do something that I have not seen, and that is you kind of lean into the, "Hey, if not everyone is going to adopt this, it's still important because the technology will enable this type of financial freedom for those that do." And I think that is a very different take than you see, where you're saying, "Hey, we need this thing to grow. That's why we're so excited when all the banks get engaged here." What would it take for the technology to grow for more users?

Lewis Rinaudo Cohen (28:32):

Yeah, it's a great question. A couple quick thoughts. One is I was fortunate to publish a piece about five years ago now in a journal called the International Financial Law Review, IFLR, with a brilliant, brilliant, brilliant gentleman named Alex Lipton. And in that we talk about the future of DeFi, going back five years, and really what we focus on is there is this need for this, for lack of a better term, true DeFi of the type we're talking about. But that really the direction of play at the institutional level, which is where you're going, the first-world level, is much more around automation. And I think where we see, even just to bring us up to today, as it were, the innovation exemption, what the SEC has said is, "Look, let's experiment with automated market maker, AMM, technology in the context of a permissioned environment." That's not in any way, shape, or form DeFi, but it's automation, and it's allowing the technology that grew up from the world of DeFi to be implemented in this new way, and let's see what happens. It's very much of an experiment. So I applaud that, and I think that idea of using this technology for automation is where the growth comes. The fact of the matter is most people just have not prized this idea of true decentralization. They understand, for example, that popular perps markets are largely controlled by a small team of people. That many of the popular systems that are used are not particularly decentralized, in whichever term you wanna use. And that's okay. That's not the end of the world.

Ari Redbord (30:13):

I love that. I think I have said for years, there has never been a world where there is a rip and replace. As you see this space developing, when I say this space, Cahill Next, really the next frontier piece to this thing, what do you see as the legal challenges, legal issues that you are going to be spending most of your time on over the next, hey, I used to say a couple of years. Now I will say, what, a couple of days? I do not know. But the six months to a year or so, what do you see as the issues that are really prescient right now?

Lewis Rinaudo Cohen (30:45):

Yeah, no, I often say, I had a tough year last week, and

Ari Redbord (30:48):

Yeah, totally. Yeah, exactly.

Lewis Rinaudo Cohen (30:51):

It feels that way. Yeah. So I think, look, I think many of your listeners know I was really involved with, and a proponent of, the principles behind the CLARITY Act. I was quite disappointed, obviously, that Congress wasn't able to make it work. I was particularly disappointed, Ari, because it failed not on principle. And look, I understand how Washington works, but nevertheless, if it was like, "Man, those were dumb ideas," fair enough. But it wasn't because they were poor ideas. It was because of extrinsic things. So that was disappointing to me. The challenges now are helping our clients navigate through this. We don't have a particularly clear standard now for what is or is not a security, how a taxonomy. Mike Selig and the CFTC came up with a fascinating idea of how do we create, through alternative means, a national framework for spot trading of crypto assets, and I commend them for that work. It is creative. We'll see where exactly it goes. But look, that's great work. The SEC, likewise, with Reg Crypto Assets, is trying to do their best. Everybody's trying to do their best, but it's going to take a lot more work than if Congress had been able to do their job and had been able to pass legislation. So a large piece of it is figuring out how do we take these disparate pieces and kind of pull them together into market practices. Business people just want rules of the road. Tell me, is it two yellow lines down the middle? Is it a dotted white line? Just tell me and I'll work with it. They get frustrated, and appropriately so, when the lawyer is like, "It depends. I don't know." Right? So that's a big piece. I think the other big piece we touched on, so I won't dwell on it here, is helping people navigate agentic finance. I was at an event at Fordham Law School. I talked a bit about this, and I told the guys afterwards, I said, "My one regret is I didn't talk more about it." This agentic activity will be, and I'm saying it here on the podcast, you got the receipt, Ari, it will be the dominant discussion in the world of finance, three months, six months, 12 months. Yeah. So we do really have to change the wings of the airplane while in flight and figure out how this all works. Because market mechanisms, I think when you study markets, when you care about markets, you realize that they have their own life. They have their own way of doing things. They respond to capital in their own ways. And once you apply technology to them, regulation is a secondary thought. I call out the work of the Venezuelan economist Carlota Perez. For those who don't know her, she's talked a lot about technological change in financial systems. Fascinating work. Great read, great author, great thinker. So everyone, TRM, Cahill, we all have to pull together and work, figure this thing out. How is it gonna work? What are sensible rules? What are the principles that we're applying? How do we make that work? And how do we ultimately help people continue in their lives, their businesses, and in their careers?

Ari Redbord (33:53):

That's amazing. Last question. What do you do when you are not the crypto lawyer in the space, when you are not writing, when you're not advising clients? What does Lewis Cohen do for fun?

Lewis Rinaudo Cohen (34:04):

Well, one thing I think people find a little bit amusing. My wife and I moved up north of the city a couple years ago to a beautiful town called Garrison, which is right across from West Point. And we had a bit of land, but it's kind of rocky up where we are and all. And my wife, who had grown up on a farm, said, "We should get goats." I'm like, "I'm sorry, what?" And she was quite serious, as spouses may be sometimes. And so we got three goats. We love them. They're wonderful. They're part of our family.

Ari Redbord (34:40):

Lewis, you are the GOAT, but I did not know you had goats.

Lewis Rinaudo Cohen (34:44):

We have three goats, and they're actually absolutely part of our family. I'll let them in the house, come wander around. Yeah, we love our goats. And they're just friends. And again, I think, Ari, things that keep you grounded. The other thing I would just say, of course, AI is so fascinating, and I told you I played around with vibe coding a Slack channel for myself with various of the different bots in the Slack channel. But I've also, I mentioned games, and I said when I was growing up, I enjoyed creating games for myself. And so I'm now vibe coding a game. Not a video game, but it has a literary connection. I'll just say that.

Ari Redbord (35:25):

Is there going to be an app store opportunity?

Lewis Rinaudo Cohen (35:30):

Could be. Could be. Could be. But that's just so much fun to think about games, systems, game mechanics, game theory, because it really connects the dots for me, what I do professionally and what I do for fun. It's systems, mechanics, and how do you create things that have a life of their own that people want to use. And so I've really been enjoying creating a game, but learning AI and learning coding and other things all at the same time.

Ari Redbord (35:58):

It is such a cool answer, and maybe my question, and I ask this of every guest, maybe my question needs to change, because I think you've discovered the thing that I've discovered at TRM, and that is there isn't your job and the thing you do for fun, right? It's all part of this cohesive life that you've built. And good for you for doing something that gives you a ton of energy and you have a lot of fun with. But also, your clients are lucky that you are as deep in this technology as you are. Lewis, thank you so much for joining TRM Talks. This was an amazing conversation. I can't wait for people to hear it.

Lewis Rinaudo Cohen (36:35):

Awesome. Ari, thank you, and thanks to the TRM team for making this possible.

Ari Redbord (36:42):

You know, I mentioned the story of Lewis and I, five years ago, spending this hour or two at a bar after an event in Philadelphia, and essentially you just heard that conversation, but five years later. And I remember at that time really talking about the intersection of privacy and security that we think so much about at TRM, right? How do we enable privacy and security? And today we really heard about what one of the leading lawyers in our space thinks about this agentic moment. What are the myriad issues that young lawyers are going to be dealing with? And I know that folks probably know this after listening, but there are really a handful of lawyers that have thought deeply about crypto and AI and blockchain and that intersection of technology and the law. Lewis is that guy. The New York Crypto Lawyer handle is epic. It immediately denotes expertise in our space. So really so cool to have this conversation with Lewis, but the coolest part for me was having it in this AI moment, right? We are sitting at the precipice of rewriting the law books for the agentic moment, and Lewis is that guy. So cool to have him on, and honestly excited to continue the conversation with him privately and publicly.

(38:09):

On the next TRM Talks, I sit down with Nick Leiserson, the president of the Center for Advancing Cybersecurity at the Institute for Security and Technology. If you love the show, leave a review wherever you're listening to it and follow us on LinkedIn to get the latest news on crypto regulation, compliance, and investigations.

TRM Labs (38:28):

TRM Talks is brought to you by TRM Labs, the leading provider of blockchain intelligence and anti-money laundering software. This episode was produced in partnership with Voltage Productions. The music for this show was provided by iKOLIKS.

Ari Redbord (38:48):

Now let's get back to building.

‍

About the guests

Lewis Rinaudo Cohen
Cahill Gordon & Reindel LLP

Lewis Rinaudo Cohen a partner and Co-Chair of CahillNXT at Cahill Gordon & Reindel LLP. He helps clients successfully navigate their most challenging transactions and regulatory compliance matters involving bleeding edge uses of blockchain technology, crypto assets, and tokenization across all aspects of the capital markets. His work frequently involves transformational cross-border fundraisings and deals across a wide array of global economic activities.

With the emergence of distributed ledger technology in 2009, Lewis, early on, identified the important role this technology would play across not only the financial markets, but virtually all aspects of the commercial landscape. He then quickly dedicated himself to advising clients in this vital area. Lewis regularly represents a wide range of high-profile blockchain development companies, foundations supporting major blockchain protocol communities, and a range of Tier 1 marketplace operators, trading firms, and other intermediaries active in the crypto asset space, with a particular focus on the complex work of structuring and launching new blockchain protocols, networks, and related crypto assets.

Lewis also brings his career-long experience advising traditional financial institutions and Fortune 500 companies on initial public equity and debt offerings and a wide range of securitization and other structured financing transactions to the emerging area of the “tokenization” of so-called “real world assets” (RWAs), a practice requiring deep knowledge of both traditional financial regulation and the rapidly changing world of blockchain regulation.

Lewis is a frequent public speaker and an influential thought leader on the topic of blockchain technology, crypto assets, and financial markets. He is regularly sought out by senior regulatory officials, legislators, and media reporters in the United States, Caribbean islands, Europe, and Asia seeking to understand how crypto assets and associated blockchain technology should be regulated.

Prior to joining Cahill, Lewis co-founded and ran one of the leading boutique law firms focused on blockchain technology, and was also a corporate partner in the New York offices of two AmLaw Global 25 firms.

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