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Overview - On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light...more
On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that...more
The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more
In the third episode of this four-part series, Ethan, Addison, and Trey discuss several state-level developments that occurred in the digital asset sector during 2023. The group discusses the inception of New York Department...more
What Happened? The New York Department of Financial Services (NYDFS or Department) released proposed updates to its guidance on the self-certification process for listing and delisting digital assets. It also announced...more
The New York Department of Financial Services (NYDFS) formally implemented its Virtual Currency Assessments Rule as 23 NYCRR 102 on Wednesday, April 19, 2023, by publishing a notice of adoption in the State Register. Under...more
On April 17, NYDFS announced the adoption of a final regulation establishing how certain licensed virtual currency businesses will be assessed for supervision and examination costs. Under 23 NYCRR Part 102, licensed virtual...more
On March 16, NYDFS issued a consent order against a payment service provider for allegedly failing to comply with the state’s virtual currency and cybersecurity regulations. The company was licensed to engage in virtual...more
In the depth of a crypto winter, the New York State Department of Financial Services (DFS) issued guidance (the Guidance) on custodial standards for those with a BitLicense or that are registered as New York state limited...more
At a time when states are jockeying for position to become digital asset and cryptocurrency hubs and we’ve witnessed turmoil and regulatory uncertainty within the cryptoasset industry, the New York Department of Financial...more
The New York State Department of Financial Services has issued an industry letter detailing the prior approval process for all New York banking organizations seeking to engage in new or significantly different virtual...more
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related...more
On June 24, 2020, the New York Department of Financial Services (the "NYDFS") announced it is considering a proposal to issue conditional licenses (a "Conditional License") for companies to begin virtual currency activities...more
On December 23, 2019, the New York Department of Financial Services (NYDFS) issued an Industry Letter instructing each institution it regulates, including banks and licensed Fintechs, to make submissions describing the...more
The New York State Department of Financial Services proposed a self-certification regime for the approval of new digital coins by licensed virtual currency firms similar to the process applied by the Commodity Futures Trading...more
A&B Abstract: In an effort to position itself as the “Regulator of the Future,” the New York State Department of Financial Services (“NYDFS”) recently launched the Research and Innovation Division, which will be responsible...more
The Situation: For the first time, the New York State Department of Financial Services ("NYDFS") publicly announced that it had denied a cryptocurrency exchange's applications for virtual currency and money transmission...more
As of February 15, 2018, banks, insurance companies, and other financial services institutions and licensees regulated by the New York Department of Financial Services (DFS) are required to file their first certification of...more
The New York State Department of Financial Services has approved the application of Gemini Trust Company to trade the digital currency ether on its platform, which is the first time the state has consented to the trading of a...more
Regulatory Developments - NYDFS Announces Approval of First BitLicense Application from a Virtual Currency Firm: The New York State Department of Financial Services (NYDFS) announced Sept. 22 that it has approved...more
Regulatory Developments: CFTC Grants Temporary Registration as SEF to LedgerX Bitcoin Options Exchange and Clearing House - On Sept. 10 the CFTC announced that it had issued an Order of Temporary Registration as a...more
The final rules’ significant operational requirements for licensees could prove to be expensive and substantial barriers to entry for small businesses interested in engaging in virtual currency business activities in New...more
This may be the year of the virtual currency. Virtual currencies have garnered much media, investor, and government attention. But, as venture capital funding continues to pour into the industry—more than $1 billion is...more
The New York State Department of Financial Services (NYDFS) released final BitLicense regulations on June 3, 2015, almost eleven months after the initial BitLicense proposal was issued. The initial proposal went through two...more