Christopher L. Boone
Chris helps clients navigate the federal and state regulatory environments that govern payment processing. He works with banks, processors, independent sales organizations (ISOs), payment facilitators, merchants, payment networks, and fintech businesses to address the legal, operational, and business challenges of payment and transaction processing.
Chris advises clients on all manner of agreements, including merchant processing and sponsorship. He also counsels on payment structures and forms of mobile and digital payments, best practices, PCI compliance, and related privacy issues.
Blockchain and Cryptocurrencies
Chris's blockchain practice focuses on regulatory compliance issues related to cryptocurrencies and token platforms. These representations include regulatory compliance counseling, state and federal money transmission guidance, structuring operations to avoid unnecessary licensing and regulatory requirements, advertising review, drafting operational policies and terms of service, government affairs, and state and federal licensing.
Advertising, Marketing, and Rewards/Loyalty Programs
Chris advises clients on a variety of advertising and marketing compliance issues, arising from claim substantiation, endorsements and testimonials, promotions, rewards/loyalty programs, and other advertising conducted through television, online, radio, and social media, among other channels. He provides counsel on marketing practices for compliance with relevant regulatory and statutory requirements, including the Federal Trade Commission (FTC) Act, the Telephone Consumer Protection Act (TCPA), the Telemarketing Sales Rule (TSR), the Restore Online Shoppers' Confidence Act (ROSCA), and the CAN-SPAM Act.
Transportation and Highway Safety
Chris focuses his transportation practice on regulatory compliance, participation in agency rulemaking proceedings, and government affairs, including interacting with Department of Transportation (DOT), Federal Highway Administration (FHWA), National Highway Traffic Safety Administration (NHTSA), Federal Aviation Administration (FAA), Hazardous Materials Safety Administration (PHMSA), and Federal Motor Carrier Safety Administration (FMCSA) officials.
Chris is deeply involved in issues relating to highway safety, and he successfully worked with the DOT and FHWA to repeal a federal rule that made it virtually impossible for states to use federal highway aid to procure products that were protected by patents or other intellectual property laws. The repeal now allows states to acquire innovative, patented, and proprietary products that make highways safer and more efficient.
Chris also advises clients on issues relating to outdoor advertising, the Highway Beautification Act (HBA), vehicle rooftop advertising, NHTSA safety standards, autonomous vehicles, and advanced crash avoidance and mitigation systems. Chris also has experience working on FAA-related matters, including air navigation hazard determinations, the preemptive effect of FAA rules, FAA release of airport property, and grant assurances related to FAA-administered airport financial assistance programs.
Related Practices
Experience
Representative Matters
Cryptocurrency and NFTs
- Advised a leading payment processor on developing and implementing underwriting and due diligence criteria for cryptocurrency and NFT merchants
- Counseled a financial platform and early-stage venture companies on development of a cryptocurrency exchange, including federal and state money transmitter licensing requirements, and the preparation of licensing applications
- Represented a cryptocurrency exchange in connection with an SEC investigation
- Advised an e-commerce merchant and a nonprofit on accepting cryptocurrency payments and donations
- Counseled an automobile manufacturer, a movie studio, and celebrities on the development of NFT programs
- Advised an NFT gaming platform on money transmission and SEC regulatory compliance
Payments and Financial Services
- Developed BSA/AML, OFAC, and other risk management policies and procedures for payments companies
- Provided policy and regulatory counsel to a leading payments industry trade group
- Advised banks, payment processors, and merchants on compliance with credit card and NACHA rules
- Counseled one of the major card brands on merchant aggregation, including payment facilitators, marketplaces, staged digital wallets, and merchants of record
- Advised a merchant acquiring sponsor bank on state and federal laws related to fantasy sports, gaming, and gambling
- Conducted regulatory due diligence of an acquisition target operating a credit repair business
- Advised an international e-commerce marketplace on development of marketplace payment models and expansion into the United States
- Advised a financial service company on developing a prepaid card program
Transportation
- Represented a leading truck manufacturer in obtaining joint Federal Motor Carrier Safety Administration (FMCSA) and Federal Highway Administration (FHWA) approval for an exemption to requirements affecting the attachment of advanced sensor technology to commercial motor vehicles
- Assisted a major airline in securing CARES Act COVID relief funds appropriated for the airline industry
- Counseled a railcar manufacturer in connection with a National Transportation Safety Board (NTSB) investigation into a derailment incident
- Counseled the leading industry association for autonomous vehicles on legal and policy issues affecting the AV industry at the federal, state, and local levels
- Successfully petitioned the Department of Transportation on behalf of a rental car company to issue a new rule allowing rental car companies to temporarily deactivate a vehicle’s knee-bolster airbags to install hand controls for disabled drivers
Telecommunications
- Counseled device manufacturers and transportation providers on FAA grant conditions and MUTCD requirements for traffic control devices
- Advised telecommunication companies on 5G spectrum auction
- Counseled emergency communication service providers and device manufacturers on e-911 compliance requirements, including drafting comments to the FCC in response to proposed rulemakings concerning location accuracy of emergency calls
- Advised merchants and marketers on compliance with the Telephone Consumer Protection Act (TCPA) and the Telemarketing Sales Rule
Advertising
- Developed loyalty and rewards programs for e-commerce merchants
- Advised merchants on developing gift card programs
- Represented an event ticket broker before the FTC in the first enforcement action brought under the Better Online Ticket Sales Act (BOTS Act)
Insights
Credentials
Education
- J.D. magna cum laude Duke University School of Law 2015
- B.A. Political Science honors and highest distinction University of North Carolina at Chapel Hill 2012
Bar Admissions
- District of Columbia
- Maryland
Professional Memberships and Activities
- LGBT Bar Association
- Electronic Transactions Association
- Guest lecturer for George Washington University Law School, Financial Technology Initiative
Recognition
- Electronic Transactions Association (ETA), Forty Under 40, 2022
- The Best Lawyers in America, Ones to Watch, 2021 – 2024
- Legal 500, Finance - Financial services regulation, 2023
Community
Pro Bono
- Works with a litigation nonprofit supporting survivors of domestic violence