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

Will Resiliency Carry the Digital Asset Sector Through 2024: State-Level Developments — The Crypto Exchange Podcast

Troutman Pepper Locke on 5/7/2024

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

NYDFS Proposes Updates to Guidance for Listing and Delisting Digital Assets

Perkins Coie on 9/29/2023

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

NYDFS Implements Virtual Currency Assessments Rule

Perkins Coie on 5/15/2023

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

NYDFS to impose supervision fees on virtual currency licensees

Orrick, Herrington & Sutcliffe LLP on 4/20/2023

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

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

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

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

New York State Department of Financial Services Outlines Prior Approval Process for Virtual Currency-Related Activity

Alston & Bird on 12/23/2022

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

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

Piggyback Ride to New York BitLicense

Sullivan & Worcester on 7/14/2020

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

NYDFS Requires LIBOR Transition Plans by Early February

White & Case LLP on 1/14/2020

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

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

NYDFS Rejects Cryptocurrency Exchange License Applications, Citing Compliance Program Flaws

Jones Day on 4/25/2019

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

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

NYS approves Gemini Trust Company to trade digital currency ether

Robinson+Cole Data Privacy + Security Insider on 5/12/2016

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

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 Rules Have Far-Reaching Effects on Virtual Currency Businesses

Troutman Pepper on 6/30/2015

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

State Regulation of Virtual Currency: A Recap

Carlton Fields on 6/25/2015

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

Plus ça change…NYDFS releases final BitLicense regulations

Davis Wright Tremaine LLP on 6/12/2015

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

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