News & Analysis as of July 18, 2025

Financial Institutions

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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 -

Association of State Financial Regulators Issues Guidance on Virtual Currency for Licensed Money Transmitters

Wilson Sonsini Goodrich & Rosati on 7/10/2025

Recognizing the evolving landscape of digital finance, the Conference of State Bank Supervisors (CSBS), an association of state financial regulators, issued advisory guidance on the treatment of virtual currency held on a...more

CSBS Issues Guidance on Virtual Currency and Tangible Net Worth

Troutman Pepper Locke on 7/9/2025

On June 26, the Conference of State Bank Supervisors (CSBS) released new guidance regarding the treatment of virtual currency in the calculation of a licensee’s tangible net worth under the Money Transmission Modernization...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

New York Department of Financial Services Issues Cryptocurrency-Related Guidance to Banks, Increases Regulatory Scope

Proskauer - Blockchain and the Law on 1/9/2023

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

Virtual Currency Activity Prior Approval Requirement Established by NYDFS

Mayer Brown Free Writings + Perspectives on 12/20/2022

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

California DFPI Issues Guidance to Financial Institutions Regarding Russia Sanctions

Goodwin on 3/18/2022

On March 4, 2022, the California Department of Financial Protection and Innovation (DFPI) issued a reminder to its financial institution licensees regarding their obligations in light of the Russian invasion of Ukraine: ...more

OFAC Sanctions Compliance Guidance for the Virtual Currency Industry

White & Case LLP on 11/22/2021

On October 15, 2021, the US Department of the Treasury’s Office of Foreign Assets Control ("OFAC") issued a brochure to promote sanctions compliance in the virtual currency industry (the "Guidance")1 and updated two related...more

OFAC Publishes New Guidance for the Virtual Currency Industry

Foley Hoag LLP - Security, Privacy and the... on 11/5/2021

The U.S Department of the Treasury’s Office of Foreign Assets Control (OFAC) has published guidance to aid members of the virtual currency industry (ranging from tech companies to brokers to users) in complying with OFAC...more

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

K2 Integrity on 10/25/2021

Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Sanctions Compliance for Crypto: OFAC Issues Guidance Targeting Virtual Currency Industry

Sheppard Mullin Richter & Hampton LLP on 10/22/2021

Last Friday, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. This guide comes on the heels...more

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on 7/7/2021

The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

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