News & Analysis as of July 19, 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 -

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 Proposes Updated Guidance on Crypto Listing

Latham & Watkins LLP on 10/6/2023

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

Crypto Products Launch for Custody, Tokenization, Staking; Crypto Adoption Report Published; DFS Proposes New VC Guidance; NFT...

BakerHostetler on 9/25/2023

Financial Firms Launch Crypto Products for Custody, Tokenization and Staking - In a recent press release, BitGo announced its plans “to create the first Bitcoin-only trust company” by partnering with Swan Bitcoin, a leading...more

Crypto trading platform reaches $1.2 million settlement to resolve alleged compliance failures

Orrick, Herrington & Sutcliffe LLP on 5/12/2023

On May 1, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of the state’s cybersecurity regulation (23 NYCRR Part 500)...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

New York Department of Financial Services Issues Crypto Guidance for Banks

Latham & Watkins LLP on 12/21/2022

Digital asset activities of licensed institutions must be approved and will be assessed for potential safety and soundness risks. On December 15, 2022, the New York State Department of Financial Services (NYDFS) issued...more

Top PHive Crypto Enforcement Notes: September Edition

Paul Hastings LLP on 9/7/2022

Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more

New Crypto Products Launch, Draft Digital Assets Bill Released, Regulators Address Stablecoins, DOJ Publishes Crypto Report, Hacks...

BakerHostetler on 6/10/2022

Fintech and Crypto Firms Announce Myriad New Crypto Product Launches - This week, a major global payments firm announced the launch of a stablecoin settlement solution that leverages technology by Fireblocks, a digital...more

Analyze This: The NYDFS Sets Clear Crypto Transaction Monitoring Expectations

Morrison & Foerster LLP on 5/5/2022

The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters....more

NYDFS Stresses Use of Blockchain Analytics for AML Compliance by Virtual Currency Businesses

Ballard Spahr LLP on 5/2/2022

On April 28, 2022 the New York Department of Financial Services (“NYDFS”) issued its Guidance on Use of Blockchain Analytics, a document directed to all virtual currency business entities that either have a NYDFS Bitlicense...more

NY DFS Approves New Stablecoin Co., Blockchain Data Solutions Announced, New Cryptocurrency Regulatory and Enforcement Actions in...

BakerHostetler on 1/11/2021

NY DFS Approves New Stablecoin Company, Crypto Financial Products Continue Growth - New York’s Department of Financial Services (DFS) recently granted a charter under New York Banking Law to a Japanese cryptocurrency firm...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - July 2020

Skadden, Arps, Slate, Meagher & Flom LLP on 8/4/2020

In this issue, we discuss the new initiatives under New York's BitLicense regime that clarify and streamline the regulatory landscape for virtual currency entities doing business within the state. We also examine the...more

Blockchain Trends and Enforcement Surrounding the New Technology

Skadden, Arps, Slate, Meagher & Flom LLP on 1/21/2020

In 2019, regulators continued to consider whether and how to regulate blockchain technology. After the two previous years that included a high number of initial coin offerings (ICOs), many of which involved allegedly...more

Ethereum Fork Successful, Solutions Target Sneakers and Browsers, EU and NY Consider Regulations, Enforcement Actions Continue

BakerHostetler on 12/16/2019

Ethereum Fork Implemented, Exchanges Expand Services, New Bitcoin Network Data - The Ethereum network’s Istanbul hard fork went forward late last week with the support of node operators, miners and cryptocurrency exchanges. ...more

NY DFS Doubles Down on FinTech, Consumer Protection, and Cryptocurrency Regulation - The New York State Department of Financial...

Jones Day on 8/16/2019

Consistent with New York's status as a financial services and technology hub, the New York State Department of Financial Services (the "NY DFS") announced on July 23, 2019 a new Research and Innovation Division (the...more

New York DFS Creates New FinTech Division

Pillsbury Winthrop Shaw Pittman LLP on 8/5/2019

On July 23, 2019, the New York Department of Financial Services announced creation of a Research and Innovation Division to keep pace with FinTech advances. NYDFS Research and Innovation Division created to keep pace with...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 to Virtual Currency Exchange: Don’t Let the Door Hit You on Your Way Out

Orrick - On the Chain on 4/19/2019

The New York Department of Financial Services virtual currency license is back in the spotlight after NYDFS announced that it had rejected the application of Bittrex Inc., a virtual currency exchange, to conduct virtual...more

Blockchain Week in Review - April 2019 #2

Perkins Coie on 4/18/2019

U.S. Developments - Blockstack Files With SEC for Regulation A+ Token Sale - Blockstack, the New York-based blockchain software provider, has announced that it intends to make a $50 million token offering that would use...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - April 2019

Skadden, Arps, Slate, Meagher & Flom LLP on 4/16/2019

In this issue, we examine the release of the much-anticipated Strategic Hub for Innovation and Financial Technology (FinHub) guidance for analyzing how U.S. federal securities laws apply to initial coin offerings, the...more

Advancements in Blockchain-Powered Property Sales and Energy Grids; New Stablecoins, Payment Products and Enforcement Actions

BakerHostetler on 4/12/2019

Blockchain Property Records Trial Completed, Energy Grid Project Continues, New Patents Granted - According to a press release issued late last week, U.K.-based firm Instant Property Network recently completed a successful...more

New Crypto Products in U.S. and Abroad, Enterprise Pilots Announced, Data Published on Cryptocurrency Scams and Money Laundering

BakerHostetler on 2/4/2019

DFS Issues New BitLicenses, Corda Gains Integration Partners, New Stablecoin Launched - Late last week, the New York State Department of Financial Services (DFS) granted the DFS BitLicense to Robinhood Crypto LLC and Moon...more

Blockchain Week in Review - December 2018

Perkins Coie on 12/13/2018

U.S. Developments - SEC Remarks on International Virtual Currency Enforcement - On December 5, 2018, Steven Peikin, Co-Director of the Division of Enforcement at the U.S. Securities and Exchange Commission (“SEC”), gave a...more

NY BitLicense Approval, Blockchain for Energy Commodities, CFTC Enforcement, Advertising Use Cases and More

BakerHostetler on 11/19/2018

New BitLicense Approval, Stablecoin Developments and BAT on Coinbase - The New York Department of Financial Services (DFS) has granted New York Digital Investment Group (NYDIG) Execution LLC the 14th BitLicense in the state. ...more

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