Adele Faure has worked in Africa, Europe and North America, as a consultant, in finance and as a firm lawyer — but now, she’s taken on a new challenge at Palo Alto-based Robinhood.
Faure is spearheading, as assistant general counsel, the regulatory and legal facets of the cryptocurrency platform for the financial services company with an app that allows users to invest in stocks, options, ETFs, and cryptocurrency without paying a commission.
She is one of a relatively small group of in-house lawyers working in the crypto space. And she’s doing it all while completing the day-to-day work for her broader legal department.
Corporate Counsel spoke with Faure about regulatory challenges in the space, how she learned about crypto and how she balances the many responsibilities of her in-house role. This interview has been edited for clarity and length.
Corporate Counsel: Did you come to Robinhood to help launch the crypto team?
Adele Faure: I did not know crypto was at all in the works when I joined. I’ve had a lot of people ask how I found a job in crypto, but the job in crypto found me. The leadership team, in coordination with a whole lot of other teams, had been weighing the issue for awhile and then decided to push this forward. I started laying the groundwork in tandem with a colleague of mine on the business team, but the regulatory issues, the legal issues that are implicated are pretty front and center.
I was part of that duo that started laying the groundwork, and then when we really decided to flip the switch, got fully staffed up, with all the engineers, and the comms people and the product people and all that. So I had to do a pretty quick ramp-up in terms of learning about the space myself to be able to do the role that I ended up having.
How did you educate yourself on crypto so quickly? What advice do you have for someone entering the space now?
I had the wonderful advantage of being surrounded by extremely strong engineers, so this is not necessarily replicable for everyone, but I think a lot of people do have what I lovingly refer to as my “crypto nerd friends.” Basically, people who just know a lot about this space and are willing to answer all your stupid questions. And there are stupid questions—there is such a thing, in my opinion—and I asked a lot of them.
Basically, our security team spent a lot of time with me. These engineers walked me through all my questions.
There’s also just a lot of resources that are online that are free. I think it was edX that had a very good Princeton course online from back in 2014. In the course of about 15 hours it laid out essentially how things worked. And you could do it in two sets of seven hours, so it’s feasible.
What skills from your previous roles were most helpful in the crypto space?
So weirdly enough, from my World Bank days, I worked for about two and a half years for the World Bank, mostly in southern Africa. I was actually based in Madagascar, was supposed to live there for two years but then there was a coup and I had to leave much earlier than anticipated.
But the real thing I learned there and then as a lawyer at a law firm [Covington & Burling] was how to talk to regulators and frame different issues for them, especially in an area where there is not always the utmost regulatory clarity, which can be the case in certain developing countries.
What are the main regulatory challenges you’ve faced in the crypto space?
Frankly, there’s not one specific regulatory challenge I would point to, it’s more the fact that this is a new, potentially transformative technology that, at least in the U.S., that is being shoehorned into old legislative frameworks that simply did not contemplate the possibility of this kind of technology. … I think the more regulatory framework that comes to this space, the better the entire ecosystem will be.
What are some of the differences between the old regulations that crypto is being shoehorned into and the regulations that you believe would be ideal?
Some of it gets really in the weeds, especially when it comes to commodities-land. The SEC one has been really well documented, about which cryptocurrencies may or may not be securities, and that’s another issue.
One that I’ve worked a lot on is the fact that there’s no federal pre-emption. We have to engage in regulatory advocacy with all of the states and determine where we need a [money transmitter] license and apply for those licenses. And the statutes are different and the requirements are different so it’s a 50-state exercise.
Obviously, investor protection is paramount, and I understand why these regulators are being extremely careful, but in terms of enabling companies in the space to flourish in the U.S., the challenges of the federal system here make it a little less competitive than it might be in another country. Because it’s hard to do that 50-state exercise. A bigger company might have the resources to do that, and we do, but for smaller companies that can definitely be more challenging.
Outside of the crypto space, do you work closely with the rest of the legal team? Or is it segmented?
It’s ever evolving and dynamic because for almost 95 percent of my time at Robinhood there was just me and the general counsel [Archit Shah]. So we leverage our external counsel pretty significantly, but basically there wasn’t the ability for me to just do crypto, but I was very focused on it.
I was also working on all the regular things you might have as in-house counsel, bread and butter, like large contracts negotiations and partnerships, or other matters related to broker-dealers regulations, or what have you.
We’ve hired some attorneys to the team, and a paralegal, so the bandwidth is better now. That’s what I mean by “we’re evolving.”
Anything else we should know about your job?
One element I really liked as I was working on crypto here at Robinhood was that a lot of the leads were also women. I was the team lead on legal, but also our product person, design, market ops, comms—a lot of the team leads were also women.
A little of my hesitation before coming into tech was due to having, from the outside, seen all the press about the negative treatment of women in tech. Coming to Robinhood and getting to work on projects like this, it was really nice to see this big group of people working together and the leadership responsibilities women had on the team.