News & Analysis as of

Virtual Currency Bank Secrecy Act NYDFS

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... more +
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 -
BakerHostetler

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

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On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

Ballard Spahr LLP

NYDFS Releases Virtual Currency Guidance for Banking Organizations

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On December 15, 2022, the New York Department of Financial Services (“NYDFS”) published an Industry Letter detailing the Department’s guidance regarding banking organizations that wish to engage in virtual currency-related...more

White & Case LLP

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

White & Case LLP on

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

Ballard Spahr LLP

Crypto Compliance Matters: NYDFS Fines Robinhood $30M for Alleged AML, Cybersecurity, and Consumer Protection Violations

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Case Involves Familiar But Instructive Regulatory Findings - The New York Department of Financial Services (“NYDFS”) made clear last week that crypto companies can be held accountable for allegedly failing to comply with...more

Mintz

Cryptocurrency - Compliance Matters

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July was a hot month for crypto enforcement, but August is off to a hot start in its own right. On August 2, 2022, the New York State Department of Financial Services (the “Department”) issued a Consent Order with Robinhood’s...more

Dechert LLP

Financial Services Quarterly Report - First Quarter 2019: A U.S. Regulatory Patchwork Quilt: Cryptocurrency and Money Transmitter...

Dechert LLP on

According to its original design, Bitcoin was intended to reduce market participants’ need to rely on “financial institutions serving as trusted third parties to process electronic payments.”1 While Bitcoin and other...more

Skadden, Arps, Slate, Meagher & Flom LLP

Rise of Blockchain and ICOs Brings Regulatory Scrutiny

In 2017, the increased adoption of blockchain technology in various industries was partially obscured by the dramatic fluctuations in the price of bitcoins and the prevalence of so-called initial coin offerings (ICOs) to...more

Morgan Lewis

The Conference of State Bank Supervisors Adopts Model Regulatory Framework for Virtual-Currency Businesses

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Addressing regulatory concerns pertaining to consumer protection, market stability, and law enforcement, the Framework expands on the CSBS draft framework released in December 2014. The Conference of State Bank...more

Morrison & Foerster LLP

The CSBS Finalizes Model Framework for Virtual Currencies

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

Morrison & Foerster LLP

“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

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