News & Analysis as of July 18, 2025

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

NYDFS Issues Guidance on Heightened Cybersecurity and Sanctions Risk from Global Conflict

Alston & Bird on 6/30/2025

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

NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

Troutman Pepper Locke on 6/27/2025

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

NY Department of Financial Services Issues Guidance to its Regulated Industry As a Result of the Ongoing Global Conflict

Bressler, Amery & Ross, P.C. on 6/24/2025

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

NYDFS, crypto payment service provider resolve AML/cybersecurity violations

Orrick, Herrington & Sutcliffe LLP on 4/13/2023

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

Don't Be Fooled – April 1st Application Deadline for New Louisiana Virtual Currency License

Hinshaw & Culbertson - Consumer Crossroads on 3/7/2023

April 1, 2023 marks the deadline to submit an application for the Louisiana Virtual Currency Business Activity License or Virtual Currency Limited Activity Registration in order to receive timely approval from the Louisiana...more

NYDFS to Crypto Custodians Proceed with Caution

Morgan Lewis - All Things FinReg on 2/10/2023

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

Global Markets May Face Risk of Virtual Currency Abuse as Russian Actors Seek to Circumvent Sanctions

K2 Integrity on 3/14/2022

The United States, the United Kingdom, and European Union have led a broad international coalition imposing a sweeping and unprecedented range of economic and financial sanctions against Russia and Belarus in response to...more

Year-end Crypto Roundup — Five Key Concepts About the U.S. Government’s Recent Actions on Virtual Currency and Ransomware

Orrick, Herrington & Sutcliffe LLP on 12/30/2021

The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

Alston & Bird on 10/20/2021

On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more

OFAC Targets Virtual Currency Exchange for Allegedly Facilitating Ransomware Attack

Ballard Spahr LLP on 9/28/2021

On September 21, 2021 OFAC issued its first sanctions designation against a virtual currency exchange by designating the virtual currency exchange, SUEX OTC, S.R.O. (SUEX) “for its part in facilitating financial transactions...more

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

WilmerHale on 7/15/2021

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

New FinCEN Anti-Money Laundering Priorities

Foley & Lardner LLP on 7/13/2021

Financial Crimes Enforcement Network (FinCEN) remains committed to combating money laundering, in all forms, in connection with the banking and financial systems. To this end, on June 30, 2021, FinCEN issued new...more

FinCEN Issues Anti-Money Laundering and Countering the Financing of Terrorism Priorities

King & Spalding on 7/8/2021

FinCEN announces eight areas of focus and advises preparation for issuance of new regulations - On June 30, 2021, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the first...more

Financial Institutions to Remain Vigilant of Ransomware Attacks as they are Facilitators of Ransomware Payments

Foodman CPAs & Advisors on 11/3/2020

On October 1, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advisory to alert Financial Institutions (FI) relating to “predominant trends, typologies, and potential indicators of ransomware and associated...more

FinCEN Issues Ransomware Advisory

Morgan Lewis - Tech & Sourcing on 10/30/2020

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued an advisory to remind US businesses about some aspects of ransomware scams and attacks. ...more

FinCEN Issues Guidance on Ransomware Attacks

Jones Day on 10/23/2020

The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more

Bridging The Week - December 2019 #2

Katten Muchin Rosenman LLP on 12/17/2019

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

New York DFS Launches Research and Innovation Division

Alston & Bird on 7/29/2019

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

Data Privacy + Cybersecurity Insider - July 2018 #4

Robinson & Cole LLP on 7/30/2018

The Federal Energy Regulatory Commission (FERC) announced on July 19, 2018, that it is directing the North American Electric Reliability Corporation (NERC) “to develop and submit modifications to the NERC Reliability...more

Data Privacy + Cybersecurity Insider - February 2018 #3

Robinson & Cole LLP on 2/16/2018

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

Your Daily Dose of Financial News

Robins Kaplan LLP on 5/15/2017

A series of cyberattacks featuring ransomware rocked the world this weekend, and the aftershocks “could linger” for a while....more

Lending Risks Associated with Virtual Currencies

Stinson LLP on 4/12/2016

The use of virtual currencies, which seemed novel just three years ago, continues to increase and gain momentum with consumers and in various business channels. As this use continues to expand, lenders may increasingly...more

Financial Services Weekly News - September 2015 #4

Goodwin on 9/24/2015

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

Financial Services Weekly News - September 2015 #3

Goodwin on 9/17/2015

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

New York BitLicense Regulations Virtually Certain to Significantly Impact Transactions in Virtual Currencies

Katten Muchin Rosenman LLP on 7/9/2015

The New York State Department of Financial Services (NYDFS) recently issued its final BitLicense regulations with respect to Bitcoin and other virtual currencies. The new regulations require the licensing of, and establish...more

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