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Financial Services Report – Winter 2020

Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more

The NYDFS Finalizes its BitLicense Proposal

On June 3, 2015, the New York Department of Financial Services (“NYDFS”) issued a final rule regarding its “BitLicense” regulatory regime (“Final Rule”). The Final Rule follows an initial proposal from July 2014 and a revised...more

“Firsts” for the World of Virtual Currencies

There have been two recent virtual currency-related actions worthy of note: (1) the Financial Crimes Enforcement Network (“FinCEN”) announced its first civil enforcement action against a virtual currency exchanger, and (2)...more

State Virtual Currency Regulatory Developments

On February 4, 2015, the New York Department of Financial Services (“NYDFS”) issued for public comment a revised proposed rule to implement a “BitLicense” regulatory regime (the “2015 Proposal”). As discussed below, the 2015...more

FinCEN Rulings Designate Certain Virtual Currency Businesses as Money Transmitters

On October 27, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings regarding virtual currency. The first administrative ruling concerns a proposed virtual currency trading and booking...more

FinCEN Issues Additional Clarifications Regarding Bitcoin and other Convertible Virtual Currency Activities

On January 30, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings that address the application of Bank Secrecy Act (“BSA”) regulations to convertible virtual currency-related...more

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