Miles Jennings is the General Counsel and Head of Policy at a16z crypto, the digital asset-focused venture capital arm of Andreessen Horowitz. He is a prominent figure in developing legal frameworks for decentralized technologies and advocating for clear regulatory guidelines for the digital asset industry. Prior to joining a16z crypto, Jennings held senior positions in the U.S. government and was a partner at the law firm Latham & Watkins ^{[1] [2] [3]}.

Education

Jennings earned his Juris Doctor (J.D.), graduating with Honors, from The George Washington University Law School between 2008 and 2011. He received his Bachelor of Arts (B.A.) in Political Science and Government from the University of South Carolina, where he served as the Student Body President from 2004 to 2008 ^[1].

Career

Early Career and Government Service

Jennings began his legal career in private practice as an associate at the law firm K&L Gates from 2011 to 2013. He then transitioned to government service, working as an attorney at the Office of the Comptroller of the Currency (OCC) from 2013 to 2016, where he focused on bank regulation, which served as a basis for working with digital assets. ^[1]​

From 2016 to 2019, he served at the U.S. Securities and Exchange Commission (SEC), holding roles as Special Counsel and later Senior Counsel within the Division of Trading and Markets. Following his time at the SEC, Jennings became Counsel for the U.S. Senate Committee on Banking, Housing, and Urban Affairs from 2019 to 2020. In this capacity, he advised then-Chairman Mike Crapo on legislative and policy issues related to digital assets, financial technology, and capital markets ^[1].

Latham & Watkins

In 2020, Jennings returned to the private sector, joining the global law firm Latham & Watkins. He was made a partner in January 2021 and went on to co-chair the firm's global Digital Assets & Web3 Practice as well as its Global Blockchain and Cryptocurrency Task Force ^{[4] [1]}. During his tenure, he became a highly sought-after legal advisor in the crypto industry, counseling dozens of Web3 startups and nearly every major venture capital firm in the space. He is credited with designing several novel token investment and Decentralized Autonomous Organization (DAO) structures that became widely used in the sector. His clients at the firm included Andreessen Horowitz, with whom he had a close working relationship prior to his employment there ^[4].

a16z crypto

Jennings joined a16z crypto in November 2023 in the newly created dual role of General Counsel and Head of Policy ^[1]. The move from a major law firm was seen by industry publications as a strategic decision by a16z crypto to deepen its policy operations and influence in Washington D.C. amidst growing regulatory scrutiny of the crypto industry ^[5].

On March 18, 2025, a16z crypto founder Chris Dixon formally announced that Jennings would serve as the firm's Head of Policy, succeeding Brian Quintenz in the role. The appointment positioned Jennings to lead the firm’s engagement with lawmakers during a period of significant legislative discussion around stablecoin and market structure bills. In his announcement, Dixon stated, "Since 2021, he’s been shaping our policy views, and this role continues that work" ^{[3] [6]}. As General Counsel, Jennings oversees all legal matters for the fund and provides legal and regulatory guidance to its portfolio companies ^[2].

Major Works and Policy Stances

Jennings is a vocal advocate for creating clear, innovation-friendly regulatory frameworks for digital assets in the United States. His work focuses on establishing new legal structures for decentralized entities and challenging the application of traditional financial laws to novel technologies ^{[7] [8]}.

DAO Legal Frameworks

A significant portion of Jennings' work has centered on resolving the legal ambiguity surrounding Decentralized Autonomous Organizations (DAOs). While at Latham & Watkins in October 2021, he co-authored "A Legal Framework for Decentralized Autonomous Organizations," which addressed critical issues such as legal liability, taxation, and contract management for DAOs ^[6].

This work culminated in his instrumental role in the creation and passage of a Wyoming law in March 2024 that established the "Decentralized Unincorporated Nonprofit Association" (DUNA). The DUNA is a new type of legal entity specifically designed to provide a legal wrapper for DAOs, granting them legal recognition and addressing liability issues for their members without compromising their decentralized nature ^[6].

"Can't Be Evil" NFT Licenses

In August 2022, Jennings and the a16z crypto team launched "Can’t Be Evil," a set of six free, open-source legal licenses created specifically for Non-Fungible Tokens (NFTs). The project was developed in collaboration with lawyers at his former firm, Latham & Watkins ^{[6] [9]}. Inspired by the Creative Commons model, the licenses aim to standardize the legal rights associated with NFTs by giving creators clear, irrevocable rights while enshrining the principle of user ownership. The goal was to provide a common legal framework to help the Web3 industry mature ^{[6] [9]}.

Regulatory Advocacy and Views

Jennings has been a prominent and vocal critic of the U.S. government's approach to cryptocurrency regulation, which he characterizes as "regulation by enforcement." He argues that the SEC, under Chair Gary Gensler, has sought to stifle the industry rather than provide a clear path to compliance. In June 2023, he stated, "Under the direction of Chair Gensler, the SEC’s endgame for crypto/web3 in the United States is about one thing: banning the technology" ^[6].

His advocacy emphasizes several key points:

• Need for Regulatory Clarity: Jennings argues that the U.S. is at risk of falling behind other jurisdictions due to the lack of a bespoke legal framework for digital assets. He contends that applying decades-old laws to new technology creates uncertainty that harms innovation ^{[2] [7]}. In a December 2025 article for a16z's "Big Ideas 2026," he wrote, "For years, mitigating legal risk replaced product strategy; engineers took a backseat to lawyers."
• Critique of the Howey Test: He has argued that the Howey Test, an 80-year-old legal standard for identifying securities, is often unsuitable for decentralized protocols ^[8]. In a September 2025 Politico interview, he stated, "The fundamental mistake that policymakers are making in the US is that they’re treating crypto through the lens of intermediated financial regulation. And the whole point of crypto is to disintermediate."
• Proactive Engagement: Under his leadership, a16z crypto has taken an assertive stance in engaging with regulators. In August 2023, the firm filed an amicus brief in the SEC's lawsuit against Coinbase, arguing that the agency's actions represented a "significant and problematic expansion of its regulatory authority" ^[6]. In March 2025, his team submitted a detailed 50-page comment letter and policy recommendation to the SEC in response to a call for public input, demonstrating the firm's proactive approach to shaping policy ^[10].
• "Third Way" Legislation: Jennings advocates for what he calls "smart regulation"—a "third way" that is distinct from traditional frameworks for securities or commodities and recognizes the unique nature of decentralized networks ^[1]. He supports market structure legislation that would create a bespoke framework for digital assets ^[10].

Awards and Recognition

In November 2023, The American Lawyer Industry Awards honored Latham & Watkins and Andreessen Horowitz with the "Best Provider Collaboration" award. The recognition was for their joint work in developing the "Can’t Be Evil NFT Licenses." Jennings was a central figure in this collaboration, bridging his role as a partner at Latham & Watkins who worked on the project and his subsequent position as General Counsel at a16z crypto ^{[9] [6]}.

Interviews

Corporate Structures and Decentralization #01

In an interview published on the YouTube channel a16z crypto on June 19, 2023, Miles Jennings discussed approaches to corporate structuring in Web3 and how legal and organizational choices interact with decentralization objectives.

Jennings characterizes decentralization as a gradual process rather than a discrete event. Within this framework, corporate structures are presented as mechanisms that influence how authority, decision-making, and accountability are allocated throughout the lifecycle of a Web3 project. Legal form, in this context, is treated as an operational component that affects governance dynamics over time.

The discussion outlines a common development path in which Web3 initiatives originate within a developer corporation, most often organized as a C Corporation. This structure is described as practical for early-stage development and capital formation. Over time, however, Jennings indicates that continued reliance on a single corporate entity may conflict with decentralization goals, particularly when control over protocol development and decision-making remains concentrated.

Jennings separates decentralized ecosystems into three primary organizational components: developer corporations, foundations, and decentralized autonomous organizations (DAOs). Foundations are described as legal entities without shareholders, typically established to manage grants, coordinate ecosystem activities, and hold certain intellectual property. While foundations can support ecosystem operations, their reliance on identifiable boards and administrators introduces governance considerations distinct from on-chain mechanisms.

DAOs are presented as governance structures intended to manage protocol-level decisions through token-based voting systems and smart contracts. According to Jennings, DAOs face unresolved legal constraints, including the absence of legal personhood, limited ability to enter into contracts, tax compliance challenges, and potential liability exposure for participants. These issues are framed as structural limitations rather than implementation failures.

As a potential response to these constraints, Jennings discusses the use of unincorporated non-profit associations (UNAs) as legal entities associated with DAOs. In his assessment, UNAs provide a framework that allows collective participation, limited liability, and flexibility in membership composition, while avoiding characteristics associated with equity ownership. Legislative efforts in several United States jurisdictions are referenced as attempts to formalize this structure for DAO use.

The interview concludes with an emphasis on multi-entity organizational models, in which responsibilities are distributed across developer corporations, DAOs, and foundations. According to Jennings, such arrangements aim to reduce centralized control while maintaining operational coordination. Decentralization, as presented in the discussion, is described as an outcome shaped by legal design choices rather than solely by technical architecture. ^[13]

Policy, Decentralization, and U.S. Crypto Regulation #02

In an interview published on April 23, 2025, on the YouTube channel Crypto In America, Miles Jennings, Head of Policy and General Counsel at a16z crypto, discussed his views on cryptocurrency regulation and its implications for the United States. The interview focused on regulatory approaches, legal structures, and institutional roles related to digital assets, as articulated from Jennings’ professional perspective.

During the conversation, Jennings described changes in the U.S. regulatory environment, noting a transition from heightened uncertainty to increased regulatory engagement, particularly in interactions with the Securities and Exchange Commission. He outlined how regulatory ambiguity in prior years influenced compliance strategies, corporate structuring, and jurisdictional decisions among crypto projects operating in or connected to the United States.

Jennings presented a regulatory framework that emphasizes the concept of control as a distinguishing factor in token classification. According to his explanation, this approach differentiates between company-backed tokens and network-based tokens by assessing the extent to which operational control is retained or relinquished. He stated that this model seeks to address information asymmetries through targeted disclosure mechanisms rather than relying exclusively on decentralization as a defining criterion.

The discussion also covered legal instruments intended to address regulatory uncertainty. Jennings referenced the use of safe harbor provisions for specific activities, including airdrops, non-fungible tokens, and memecoins, as well as the adoption of entity structures such as Wyoming’s Decentralized Unincorporated Nonprofit Association. He described these mechanisms as methods for providing formal legal recognition to decentralized governance arrangements while limiting liability exposure.

In addition, the interview examined the broader policy context, including legislative developments related to market structure and stablecoin regulation, as well as the distribution of regulatory authority between federal agencies. Jennings commented on the potential role of the Commodity Futures Trading Commission in overseeing digital commodity markets, including spot market activity, in light of ongoing policy discussions.

The interview reflects Jennings’ assessment of how regulatory definitions, legal frameworks, and inter-agency coordination may influence the operation of crypto-related projects within the United States. The discussion remains focused on regulatory design and institutional processes rather than advocacy for specific outcomes. ^[14]