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Overview - On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light...more
On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that...more
The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more
On January 12, NYDFS announced that it had entered into a consent order with a digital currency trading company after an investigation that found the company responsible for compliance failures that violated NYDFS’s virtual...more
Following a two-month public consultation period, on 15 November 2023 the New York State Department of Financial Services (NYDFS) published its new Virtual Currency Listing Guidance (the Guidance), in accordance with virtual...more
On May 1, the New York Department of Financial Services (“NYDFS” or “Department”) and a trading platform entered into a consent order to resolve deficiencies identified during examinations conducted in 2018 and 2020. The...more
On May 1, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of the state’s cybersecurity regulation (23 NYCRR Part 500)...more
On March 16, NYDFS issued a consent order against a payment service provider for allegedly failing to comply with the state’s virtual currency and cybersecurity regulations. The company was licensed to engage in virtual...more
In the depth of a crypto winter, the New York State Department of Financial Services (DFS) issued guidance (the Guidance) on custodial standards for those with a BitLicense or that are registered as New York state limited...more
Louisiana has become the first state to follow New York's lead in issuing a crypto-specific license, accepting Louisiana Virtual Currency Business Activity (VCBA) license applications as of January 1, 2023. All entities...more
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
On January 4, 2023, the New York State Department of Financial Services issued a consent order against Coinbase, a virtual currency company. Pursuant to the consent order, Coinbase will be paying a $50 million penalty to the...more
On August 1, 2022, the New York State Department of Financial Services (“DFS” or “Department”) issued a Consent Order, imposing a $30 million fine on Robinhood Crypto, LLC (“Robinhood”), a trading platform that allows...more
The New York State Department of Financial Services proposed a self-certification regime for the approval of new digital coins by licensed virtual currency firms similar to the process applied by the Commodity Futures Trading...more
Consistent with New York's status as a financial services and technology hub, the New York State Department of Financial Services (the "NY DFS") announced on July 23, 2019 a new Research and Innovation Division (the...more
On July 23, 2019, the New York Department of Financial Services announced creation of a Research and Innovation Division to keep pace with FinTech advances. NYDFS Research and Innovation Division created to keep pace with...more
A&B Abstract: In an effort to position itself as the “Regulator of the Future,” the New York State Department of Financial Services (“NYDFS”) recently launched the Research and Innovation Division, which will be responsible...more
As of February 15, 2018, banks, insurance companies, and other financial services institutions and licensees regulated by the New York Department of Financial Services (DFS) are required to file their first certification of...more
As legislators grapple with creating legislation intended to bring virtual currencies, such as bitcoin, within the scope of anti-money laundering regulations, the vulnerability of Bitcoin exchanges to theft and other cyber...more
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
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
Regulatory Developments - NYDFS Announces Approval of First BitLicense Application from a Virtual Currency Firm: The New York State Department of Financial Services (NYDFS) announced Sept. 22 that it has approved...more
Regulatory Developments: CFTC Grants Temporary Registration as SEF to LedgerX Bitcoin Options Exchange and Clearing House - On Sept. 10 the CFTC announced that it had issued an Order of Temporary Registration as a...more
The New York Department of Financial Services (NYDFS) made history last summer when it proposed Bitcoin regulations (reportedly the first in the nation) including the requirement that financial firms handling virtual...more