News & Analysis as of July 18, 2025

New York

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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

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 Attorney General Proposes Comprehensive and Restrictive Digital Assets Bill

Morgan Lewis on 6/22/2023

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

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

NY DFS Releases Custodial Guidance on Crypto Insolvency

Sheppard Mullin Richter & Hampton LLP on 2/3/2023

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

Coinbase Agrees To Settlement With New York Regulator

Shipkevich PLLC on 1/6/2023

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

New York State Department of Financial Services Imposes $30 Million Fine in First Cryptocurrency Enforcement Action

White & Case LLP on 8/15/2022

On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its...more

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