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 -

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

Bit by bit: improving consumer complaint processes in crypto

A&O Shearman on 6/19/2024

On May 30, 2024, the New York State Department of Financial Services ("NYSDFS" or the "Department") issued guidance to all virtual currency businesses licensed or chartered with the Department ("VCEs"), including those...more

Client Alert: Virtual Currency Update: NYDFS Issues Key New Guidance As It Marks Two Year Milestone

Jenner & Block on 10/9/2023

The New York Department of Financial Services (NYDFS) proudly announced an “update on [its] two-year transformational initiative to strengthen NYDFS’ nation-leading virtual currency oversight” on September 18, 2023. Although...more

Fake It Till You Make It: The Travel Rule And Virtual Currencies

King & Spalding on 10/2/2019

The Travel Rule is an old friend for those familiar with banking regulations and anti-money laundering rules. The Rule, first issued by FinCEN in 1995 with fiat currency in mind, requires banks and nonbank financial...more

PA Department of Banking and Securities: Virtual Currency is not “Money”

Ballard Spahr LLP on 1/25/2019

Typical Virtual Currency Exchanges Do Not Require PA Money Transmitter Licenses - The Pennsylvania Department of Banking and Securities (“DoBS”) just released Guidance declaring that virtual currency, “including Bitcoin,”...more

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