Crypto Currently: New York Department of Financial Services Issues Updated Expectations on the Adoption or Listing of Virtual Currencies

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On September 18, the New York State Department of Financial Services (the DFS or the “Department”) issued proposed guidance for BitLicensees and limited-purpose trust companies (collectively, VCEs) seeking to list virtual currencies on their platforms. The proposed guidance updates the Department’s framework for self-certification of coins and establishes new policy requirements for coin listings and delistings (Proposed Guidance). Concurrently, the Department updated its list of coins that VCEs can list without the DFS’s prior approval (the Greenlist) and revised the process for coins to be added to the Greenlist (the General Framework for Greenlisted Coins).

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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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