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Jorge Pesok

Phone: +1 212.803.4073
590 Madison Avenue, 20th Floor
New York, NY 10022-2544

Jorge Pesok is a counsel in Crowell & Moring’s White Collar & Regulatory Enforcement and Blockchain and Digital Assets practices in the New York office.

Jorge’s practice focuses on white collar defense, internal investigations, complex litigation, compliance counseling, and the legal and regulatory issues faced by emerging and established digital asset/blockchain companies. His work includes representing clients in enforcement and litigation matters before the SEC, DOJ, CFTC, and CME. Jorge also counsels blockchain and distributed ledger technology clients on the application of federal and state securities, commodities, and money transmission laws.

A decorated veteran, Jorge served on active duty in support of Operation Iraqi Freedom, where he was awarded the Army Commendation Medal. Jorge retired from the U.S. Army National Guard in 2014 after serving eight years in the Judge Advocate General Corps and obtaining the rank of sergeant.

Selected Blockchain/Digital Asset Engagements

  • Defense of SAFT issuer in investigation by the SEC into whether its SAFT constituted an unregistered security offering. Result: non-public declination by the SEC with no penalties or adverse action. 
  • Defense of a digital asset company and individuals in a class action lawsuit alleging that the company’s issuance of a digital asset constituted an unregistered securities offering. 
  • Advise money remittance company using a digital asset for remittances on response to subpoena from the SEC and in contract negotiations.
  • Represented a blockchain-based distributed computing platform that issued a native digital token in a securities class action lawsuit filed in New York alleging violations of the U.S. securities laws.
  • Represented a distributed ledger technology company as part of an informal inquiry into its private and public token offerings.
  • Counseled a digital asset trading platform and other entities that utilize blockchain and related novel technologies on the application of federal and state securities and transmission laws.
  • Developed AML / Bank Secrecy Act (BSA) / Office of Foreign Assets Control (OFAC) compliance policies and procedures for a digital asset trading platform.
  • Drafted and implemented a digital asset token review protocol to reduce the risk of listing unregistered securities.
  • Advised a digital asset trading platform on its terms of service.

Selected White Collar & Regulatory Enforcement Engagements

  • Represent multinational agriscience company in an internal investigation of potential FCPA violations in Paraguay, and related conduct in Brazil and Argentina.
  • Represent an investment advisor firm in SEC enforcement investigation regarding disclosure to fund investors and potential violations of fiduciary duties.
  • Conducted internal investigation for NYC based holding company related to potential FCPA violations in Peru.
  • Represented Mexican company in investigation by the SEC regarding its financial disclosures related to its ADRs listed on NYSE.
  • Represented a national accounting firm in connection with investigations by the CFTC, DOJ, NY AG, and others.
  • Represented a Fortune 100 company in FCPA investigations in India.
  • Represented an ETF promoter in an SEC investigation regarding various trading and ‘40 Act issues.
  • Represented a publicly held manufacturer and distributor of wood and wood products in connection with investigations by DOJ and SEC.
  • Represented an employee of a publicly traded company in an investigation by the SEC into misstated earnings.
  • Represented a broker-dealer in an arbitration related to excessive mark-ups on fixed income securities transactions.
  • Represented a multinational bank in a CME investigation regarding alleged spoofing by one of its traders.
  • Represented an individual in a CME investigation regarding alleged spoofing.


  • University of Connecticut, B.A. (2011)
  • University of Minnesota Law School, J.D. (2014)


Admitted to practice: District of Columbia, New York, and the U.S. District Court for the Southern District of New York.

View More

"SEC Continues Enforcement Push against ICO Issuers by Imposing Penalty Against Unikrn of Substantially All its Assets," White Collar Alert (September 21, 2020). Contacts: Michelle Ann Gitlitz, Richard B. Holbrook Jr., Jorge Pesok
Client Alert / Newsletter
SEC Shuts Down Unikrn For Its $31M 2017 ICO, Commissioner Hester Peirce Dissents Crypto Briefing (September 15, 2020)
Media Mentions
A Legal Asset After All? Governments Are Cashing In On Seized Crypto Cointelegraph (September 1, 2020)
Media Mentions
"In-Kind Returns Alone Shouldn't Qualify Tokens As Securities," Law360 (July 22, 2020). Author: Jorge Pesok.
"Cross-Border Digital Asset Payments: What You Need to Know About Regulations in the U.S. and Canada," Crowell & Moring Webinar (July 16, 2020). Presenters: Michelle Ann Gitlitz, Ambassador Robert Holleyman, Carlton Greene, and Jorge Pesok.
"NYDFS and OCC Announce Major Overhauls Important for Virtual Currency Businesses," International Trade Bulletin (July 8, 2020). Contacts: Michelle Ann Gitlitz, Carlton Greene, Jorge Pesok, Nicole Sayegh Succar
Client Alert / Newsletter
"What Telegram’s Settlement With The SEC Tells Us About Future Cryptocurrency Enforcement Actions And Litigation Strategies," The TIE Quarterly (July 2020). Author: Jorge Pesok.
DEAL NOTE: Crowell & Moring Advises Hacker Noon in $1 Million Investment from Coil (Jun.10.2020)
Firm News / Announcement
"FinCEN Director Identifies Virtual Currency Compliance Risks and COVID-19 Related Issues at Consensus 2020 Conference," White Collar Alert (May 20, 2020). Contacts: Caroline E. Brown, Michelle Ann Gitlitz, Carlton Greene, Jorge Pesok, Nicole Sayegh Succar
Client Alert / Newsletter
"SEC Telegram Injunction Is A Wakeup Call For Token Investors," Law360 (April 21, 2020). Authors: Michelle Ann Gitlitz, Richard B. Holbrook, Jr., Jorge Pesok, and Kayvan M. Ghaffari.

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Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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