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Piggyback Ride to New York BitLicense

On June 24, 2020, the New York Department of Financial Services (the "NYDFS") announced it is considering a proposal to issue conditional licenses (a "Conditional License") for companies to begin virtual currency activities...more

New York Proposed Guidance on Virtual Currencies

On December 11, 2019, the New York State Department of Financial Services ("DFS") issued two proposed changes to the regime that is in place in New York for the regulation and licensing of virtual currency ("VC") businesses....more

Whistleblower Policies

On January 7, 2019, the New York State Department of Financial Services (the "DFS") issued new guidance on whistleblowing programs ("WP") to all entities regulated by the DFS regardless of industry, size or number of...more

Object Lesson on How Not to Respond to Consent and Enforcement Actions

Last week, the DFS announced an enforcement action and charges against the NY Branch of Habib Bank, a Pakistani bank that had been doing business in NY for almost 40 years....more

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