Episode 5: Business Divorce, Delaware Style
In Short - The Situation: Following a string of bankruptcies among virtual currency firms, the New York Department of Financial Services has issued guidance on the practices and procedures it expects from certain...more
The Guidance clarifies the regulator’s expectations on safekeeping customer digital assets, and the disclosures that must accompany such arrangements. On January 23, 2023, the New York Department of Financial Services...more
As we first warned last summer, crypto property held in a custodian-controlled account could become the property of that custodian in the case of a bankruptcy filing. At the time, we recommended that crypto investors avoid...more
The Office of the Comptroller of the Currency (“OCC”) recently signaled its approval for banks to fully wade into the cryptocurrency custodian space. On in a July 22, 2020 interpretive letter, the OCC concluded that a...more