Ari Redbord (00:02):
I’m Ari Redbord and this is TRM Talks. I'm Global Head of Policy at TRM Labs, we provide blockchain intelligence software to support law enforcement investigations and to help financial institutions and cryptocurrency businesses mitigate financial crime risk within the emerging digital asset economy. Prior to joining TRM spent 15 years in the US federal government, first as a prosecutor at the Department of Justice, and then as a 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 crypto ecosystem who are working to build a safer financial system.
(00:52):
On today's TRM Talks, I sit down with my friend and the new managing partner of Bellementis, Teresa Goody Guillén. But first, Inside the Lab, where I share data-driven insights from our blockchain intelligence team. On today's Inside the Lab, we're talking about latency, because in this ecosystem, delay equals exposure. With illicit volume reaching 158 billion in 2025 and billions moving within minutes during major incidents, real-time ingestion is not an optimization, it's survival. Real-time blockchain ingestion means transactions are processed as they confirm, normalized across chains and made immediately available for clustering, risk scoring, and network expansion. This changes investigative posture from retrospective analysis to live situational awareness. If funds are moving across five chains within 10 minutes, you cannot afford hourly data refresh cycles. You need contextual scoring and entity mapping in operational timeframes. In digital finance, velocity is the threat multiplier. Real-time analytics is the countermeasure.
(02:04):
For much more on this, read the blog post from our engineering team on how they ingest blockchains in real time. And now, Teresa Goody Guillén. Today, I am joined by my friend, the founding partner of Bellementis, and really one of the great legal minds in our space, Teresa Goody Guillén.
Teresa Goody Guillén (02:25):
Thanks. It's great to see you. Great to talk to you.
Ari Redbord (02:28):
Would you talk a little bit about your journey to becoming, I think, really one of the true expert lawyers in this space?
Teresa Goody Guillén (02:34):
My journey, I think, is important in understanding too, how I do approach all of this, because the journey is how my mind has evolved and how my thinking has evolved and my approaches. And I was really fortunate to have some amazing mentors, something that I think is underrated these days and harder to find. But I started my career actually in law school, going to school at night. So I put myself through college and law school and working full-time. And I worked at a plaintiff's law firm, which was a different experience certainly from now. And it was really helpful at the beginning because plaintiff's law firms are a bit scrappy, and you get the opportunity to do so many things that sometimes it takes people 10 years of their career to get to. So starting at a plaintiff's law firm was really helpful. I was fortunate it was one of the top, I think, 50 lawyers, trial lawyers in the United States, and so medical malpractice and other types of plaintiff's injuries.
(03:42):
But at the highest level, it was Patrick Reagan. He actually was one of the reasons that helped me get a clerkship later on in my career was the fact that I had worked for him.
Ari Redbord (03:52):
But you mentioned mentors, which a lot of people, young lawyers in particular, I think are listening to the show. And I often talk about, I did a federal clerkship in North Carolina for a really extraordinary judge named Mac Howard, Malcolm Howard. He passed away recently. He's buried in Arlington. Just an amazing guy, Reagan appointee so many years ago. And just like you have these people in your life who've really shaped it, it sounds like, I know you clerked for Judge Urbina in the DC District Court, place where I practiced for many years as well. Tell me about that experience for sure.
Teresa Goody Guillén (04:22):
That really shaped my career immensely. And the reason I did a clerkship first was I didn't feel like I was ready to practice law. And it's amazing how much confidence I got from that experience because after I saw what people were doing, I though, "Oh, I can do this."
Ari Redbord (04:37):
Talk to me a little bit about your time at the SEC.
Teresa Goody Guillén (04:40):
It was very helpful coming from criminal defense work and investigations, civil and criminal work that I did at a big law firm, and then transitioning over to see from the regulator standpoint and the other standpoint. And it was really helpful just to see the operations even. And the resources constriction, more operational type of things were very insightful to me and how it functioned and how people think. I started litigating on behalf of the commission and then working more on some of the investigations that were going on internally. And this was after the financial crisis, which was one of the reasons that drew me there because with the financial crisis, I wanted to understand more about why that happened. How does that happen? What are our systems in place that keep that from happening or are involved in that where the guardrails? And so it was a lot of, again, my curiosity is what led me to the SEC, just being in this moment in time of wanting to know more about it.
(05:50):
And so I really took that opportunity to learn. Luckily, I was in the office of the general counsel's office, so I could do this. All the different divisions. I had to work with all the different divisions for everything that I was working on. And so I learned a lot about enforcement, and then it was moving. So Harvey Pitt, former SEC chairman, approached me really from the SEC and asked me to come work with him. So otherwise I would've stayed there longer. But how could I not accept a job with Harvey Pitt? The opportunity to work alongside one of the most brilliant, I think, lawyers who's ever practiced. I learned to know and love the commission and securities laws even more with him and almost through his eyes. So that's another mentor who just completely changed the way that I think, the way that I lawyer.
Ari Redbord (06:45):
You mentioned obviously becoming this expert on SEC, on securities law, your time in the commission, your time working with Harvey Pitt. I know you've worked at large law firms doing this today, but is there a moment when digital assets really became front and center for you?
Teresa Goody Guillén (07:02):
Yes, it's very clear in my mind. And so in 2015, Harvey, it was the first time somebody paid for my school, he sent me to go get an MBA. So I got an MBA and I decided I wanted to launch my own law firm for the first time. But my first client wanted to do a swaps transaction, and the underlying asset was a digital asset. And there was no swaps regime. There were thousands of pages of proposed rules. There was nothing on digital assets yet. And so I looked at it and I said, "Well, I could see this could be a commodity or a security. I can see the argument on both sides." So I called my friends at the SEC and my friends at the CFTC, and they both said,"Yes."
Ari Redbord (07:47):
No idea.
Teresa Goody Guillén (07:49):
Yes, I have jurisdiction.
Ari Redbord (07:50):
Yeah, exactly.
Teresa Goody Guillén (07:51):
And I was like, "Oh, that's so funny. You guys can't both have jurisdiction. Let's all get a room and chat and just talk this out."
Ari Redbord (07:57):
10 years later, it has not been worked out.
Teresa Goody Guillén (08:00):
Finally we do have Paul Atkins and Selig talking.
Ari Redbord (08:05):
Exactly. That's cool. I love that perspective. That's amazing. And then honestly, was it from that first sort of engagement with a client that you realized, "Hey, this is a really interesting issue and I can have a unique perspective on it?"
Teresa Goody Guillén (08:16):
Yeah, it was. I always look at what is the goal you're trying to accomplish? How can we accomplish this goal when it looks like we can't do it this one way? And it was interesting because I had a lot of clients who came to me and I said, "Well, we can do your transactions one way, but that would be a securities transaction, so we have to follow one of the exemptions and do it that way. Or we can change a little bit of the model that you're using right now. And if we can implement some technological changes, then we can put it into a different kind of category." And so two things, we can do it either way and I can find either solution. And they said, "Well, there's this big law firm and they said I can just do it this way." Okay, well, I do defense work too, so keep my card.
(09:12):
And so that really fascinated me. And then I don't know, you can't how people practice in this space without understanding the technology. So I taught digital law and policy at Georgetown too. And I remember the first painful time for the engineers, not painful for me, where we were walking through lines of code of a smart contract and they were explaining to me what it did, and then I would tell them the legal implication of each of those. And it was a very helpful experience for me, although painful for them, I think.
Ari Redbord (09:45):
Totally. It's so important. People ask all the time, it's like, "Hey, how can I get more involved in this space or understand it better?" And I'm always like, "Look, the space is the technology and you've got to really start to understand it. I do not at all profess to be a data scientist or an engineer, but I've really tried to touch this stuff and play with it and spin up a MetaMask wallet and mess with NFTs and fund a liquidity pool and work through those issues. I think it becomes really powerful in terms of your ability to engage with clients in that way. What are the major issues that clients are coming in with today in terms of your practice? And then I think there's a lot of questions right now, especially for US developers. While we have some really good guidance, if you will, from the SEC today that we didn't have even a few months or certainly a few years ago, CFTC, US Treasury, the Fed, we still don't have legislation.
(10:43):
How are you thinking about navigating that right now for your clients?
Teresa Goody Guillén (10:48):
Well, I have a lot of conversations with regulators like I used to before the last administration. It's a similar approach that I had taken for most of my career is going and talking to the regulators. And so we have a product, we have something, I'm working through a few different exemptive programs. People don't realize the breadth of the exemptive relief from the SEC and the CFTC, and it's nothing novel. Harvey and I used to do this all the time, going to the SEC and asking them for some exemptive relief because you can basically exempt anyone or any transaction or any instrument. As long as it fulfills certain requirements, then you get these exemptive relief. So I'm working doing that considerably. I talk to the crypto task force and make sure that what we're thinking about is not inconsistent. Obviously they can't provide me with any kind of specific information, but we want to make sure that the way that we're thinking about this is not something that's inconsistent with what the commissions are going to be doing or wanting to do.
(11:58):
But they could fully regulate the markets without any legislation. I think legislation is really helpful and is necessary certainly at some point to have things codified, but their exemptive relief collectively would enable them to regulate the markets efficiently and effectively.
Ari Redbord (12:15):
You're doing this really from a different platform. You left leading two practice groups at a large law firm to start your own thing, which as someone who joined a seven-person startup six years ago after a time in the government, it's like there's nothing I admire or respect more than someone who takes that step. You're building Bellementis. I think of it as this whole group of experts on securities, on market structure coming together in a technology-first type of way to build maybe a new model of law firm. But I also want to start with Bellementis. Tell me about the name.
Teresa Goody Guillén (12:50):
So the name means roughly, not exactly, but A Beautiful Mind. And I am a fan of John Nash and everything. I do use some of that in the game theory in my legal work, but it's more of, to me, the law is this beautiful craft. And we don't see that as much. We don't see people practicing it as this craft. It's one of the oldest crafts, and it is so beautiful. And the thought process and the minds and the thinking of it to me is just, it's so fun. I get lost in it. This is why I write my own legislation in my spare time because I just love it. It's so fascinating to me and all these puzzles. And so a lot of it is preserving this beautiful craft as a craft. So we're very selective in the people who work at Bellementis. They all are extraordinarily high quality.
