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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
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
The Proposed Guidance would require enhanced criteria for coin-listing and delisting procedures for New York-licensed virtual currency entities. On September 18, 2023, the New York Department of Financial Services (DFS)...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
Adrienne Harris, Superintendent of the New York State Department of Financial Services (“DFS”) issued an update on the VOLT initiative, an ongoing project to enhance DFS’s role as a virtual currency regulator. Superintendent...more
New York Attorney General Letitia James introduced on May 5, 2023 a proposed bill that, if enacted, would significantly tighten regulation over digital asset market participants and exchanges. While the New York State...more
On May 1, the New York Department of Financial Services (“NYDFS” or “Department”) and a trading platform entered into a consent order to resolve deficiencies identified during examinations conducted in 2018 and 2020. The...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, the NYDFS announced the adoption of final regulations intended to shift the cost of supervision and examination of BitLicensees from the NYDFS via the implementation of direct assessments to licensees. The new...more
On April 17, the Superintendent of the New York Department of Financial Services (NYDFS), Adrienne A. Harris, announced that the NYDFS adopted a final regulation establishing how companies with NYDFS-issued BitLicenses will...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
On February 21, NYDFS Superintendent Adrienne A. Harris announced enhancements to the Department’s ability to detect fraud in the virtual currency industry. The new enhancements will improve NYDFS’s ability to combat...more
In Short - The Situation: Following a string of bankruptcies among virtual currency firms, the New York Department of Financial Services has issued guidance on the practices and procedures it expects from certain...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
On January 23, the New York State Department of Financial Services (DFS or the Department) issued guidance clarifying its expectations for New York-based virtual currency businesses regarding the custody of customer assets...more
The Guidance clarifies the regulator’s expectations on safekeeping customer digital assets, and the disclosures that must accompany such arrangements. On January 23, 2023, the New York Department of Financial Services...more
On January 23, the NY DFS released updated guidance with regard to better protecting consumers in the event of virtual currency insolvency. This updated guidance applies to entities that DFS has licensed or chartered to hold...more
On January 23, NYDFS reiterated expectations for sound custody and disclosure practices for entities that are licensed or chartered to custody or temporarily hold, store, or maintain virtual currency assets on behalf of...more
On January 23, 2023, New York Department of Financial Services (DFS) released regulatory guidance to better protect customers in the event of virtual currency insolvency. The guidance is not binding, but rather persuasive...more
On January 4, 2023, the New York State Department of Financial Services issued a consent order against Coinbase, a virtual currency company. Pursuant to the consent order, Coinbase will be paying a $50 million penalty to the...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
The fiscal year 2022-2023 budget for New York, which takes effect in two months, includes requiring the New York Department of Financial Services (NYDFS) to charge a new “assessment” to all virtual currency businesses...more
New York’s slogan “if you can make it here, you can make it anywhere” seems like it was written specifically for cryptocurrency companies. Since 2015, the New York Department of Financial Services (NYDFS) established a...more
The New York State Department of Financial Services (the “NYDFS”), as a part of a series of virtual currency initiatives, proposed in June a framework for applying for and obtaining a virtual currency Conditional BitLicense....more