On July 17, the New York State Department of Financial Services (DFS) issued proposed regulations delineating a license process for certain businesses involved in Bitcoin and other virtual currencies (Proposed Rules). The Proposed Rules would require any business that engages in "virtual currency business activity" (Virtual Currency Firms) to obtain a license from DFS (BitLicense) and would require such businesses to adopt consumer protection, anti-money laundering and cyber security procedures and requirements.

A 45-day public comment period for the Proposed Rules commenced on July 23. The Proposed Rules may be revised and reissued by DFS following the review of the public comments.

Please see full advisory below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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