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BitLicense Cryptocurrency

Troutman Pepper

Will Resiliency Carry the Digital Asset Sector Through 2024: State-Level Developments — The Crypto Exchange Podcast

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In the third episode of this four-part series, Ethan, Addison, and Trey discuss several state-level developments that occurred in the digital asset sector during 2023. The group discusses the inception of New York Department...more

BakerHostetler

USDC Integrations Announced; Crypto Guidance Published by IRS, EU Banking Authority; Crypto Firm Consents to $8M Penalty; Illicit...

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USDC Report Published, Crypto Firms Announce USDC Integrations - Circle, the U.S. fintech company that manages the stablecoin USDC, recently released the “State of the USDC Economy” report, highlighting the “efforts to...more

Ballard Spahr LLP

California Reconsidering the “Digital Financial Assets Law”

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As readers may recall, California previously attempted to enact a “Digital Financial Assets Law” with the introduction of AB 2269 in February 2022. In relevant part, AB 2269 proposed (1) a stringent licensing requirement for...more

WilmerHale

New York Attorney General James Proposes Landmark Digital Asset Law

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On May 5, New York Attorney General Letitia James announced a landmark legislative proposal—titled the Crypto Regulation, Protection, Transparency and Oversight (CRPTO) Act (hereinafter, the Proposal)—to tighten regulations...more

Morgan Lewis

New York Attorney General Proposes Comprehensive and Restrictive Digital Assets Bill

Morgan Lewis on

New York Attorney General Letitia James introduced on May 5, 2023 a proposed bill that, if enacted, would significantly tighten regulation over digital asset market participants and exchanges. While the New York State...more

Orrick, Herrington & Sutcliffe LLP

Top 5 Takeaways from NYDFS $1.2 Million Fine in Cybersecurity Case

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

Orrick, Herrington & Sutcliffe LLP

NYDFS calls its virtual currency framework the “gold standard”

On May 25, NYDFS Superintendent Adrienne Harris testified before the New York assembly to address the regulation of virtual currency in the state. Harris highlighted the value and “gold standard” set by NYDFS’s virtual...more

BakerHostetler

NYS DFS Focuses on Cybersecurity Violations and Increasing Crypto Resources

BakerHostetler on

On May 1, 2023, the New York State Department of Financial Services (DFS or Department) issued a consent order (Consent Order), imposing a $1.2 million fine on bitFlyer USA, a cryptocurrency trading platform and custodial...more

Ballard Spahr LLP

NYDFS releases final regulations implementing virtual currency licensee assessments

Ballard Spahr LLP on

On April 17, the NYDFS announced the adoption of final regulations intended to shift the cost of supervision and examination of BitLicensees from the NYDFS via the implementation of direct assessments to licensees. The new...more

Troutman Pepper

New York Department of Financial Services Adopts Virtual Currency Assessments Regulation

Troutman Pepper on

On April 17, the Superintendent of the New York Department of Financial Services (NYDFS), Adrienne A. Harris, announced that the NYDFS adopted a final regulation establishing how companies with NYDFS-issued BitLicenses will...more

Orrick, Herrington & Sutcliffe LLP

NYDFS to impose supervision fees on virtual currency licensees

On April 17, NYDFS announced the adoption of a final regulation establishing how certain licensed virtual currency businesses will be assessed for supervision and examination costs. Under 23 NYCRR Part 102, licensed virtual...more

Morgan Lewis

Illinois Proposes BitLicense Regime and Other Digital Asset Laws

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Recent legislative proposals would, among other things, overhaul the Illinois money transmitter law to create a licensing framework similar to New York’s BitLicense regime....more

Latham & Watkins LLP

Blockchain Regulatory Certainty Act Would Protect Non-Custodial Crypto Services

Latham & Watkins LLP on

The bipartisan bill would provide a federal safe harbor for non-custodial blockchain service providers from state money transmission and digital asset licensing laws. On March 23, 2023, US House of Representatives...more

Latham & Watkins LLP

Illinois Considering Crypto Licensing

Latham & Watkins LLP on

A legislative initiative in Illinois would establish licensing and consumer protection requirements for digital asset businesses serving consumers in the state. On February 21, 2023, the Illinois Department of Financial...more

Jones Day

New York Department of Financial Services Issues Guidance on Virtual Currency Custodial Services

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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

WilmerHale

Crypto Currently: New York Department of Financial Services Issues Virtual Currency Custody Guidance

WilmerHale on

On January 23, the New York State Department of Financial Services (DFS or the Department) issued guidance clarifying its expectations for New York-based virtual currency businesses regarding the custody of customer assets...more

Alston & Bird

New York State Department of Financial Services Outlines Prior Approval Process for Virtual Currency-Related Activity

Alston & Bird on

The New York State Department of Financial Services has issued an industry letter detailing the prior approval process for all New York banking organizations seeking to engage in new or significantly different virtual...more

Sheppard Mullin Richter & Hampton LLP

NYDFS Provides Guidance on the Use of Blockchain Analytics to Maintain Compliance

On April 28, the New York Department of Financial Services (NYDFS) provided a “Virtual Currency Guidance” update.  The guidance is directed towards all virtual currency businesses licensed under 23 NYCRR Part 200 (the New...more

Sheppard Mullin Richter & Hampton LLP

New York’s Superintendent of Financial Services Addresses BitLicense Delays

This January, Adrienne A. Harris was confirmed as superintendent of New York’s Department of Financial Services, which administers New York’s BitLicense program, among others.  In a March 28 interview, Harris discussed the...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - July 2020

In this issue, we discuss the new initiatives under New York's BitLicense regime that clarify and streamline the regulatory landscape for virtual currency entities doing business within the state. We also examine the...more

Carlton Fields

New York's Relaxed BitLicense Could Still Take Lessons From Wyoming's Permissive Approach

Carlton Fields on

New York’s slogan “if you can make it here, you can make it anywhere” seems like it was written specifically for cryptocurrency companies. Since 2015, the New York Department of Financial Services (NYDFS) established a...more

Perkins Coie

Blockchain Week in Review - July 2020 #2

Perkins Coie on

US Developments - CFTC and SEC Issue Orders Filing and Settling Charges with Two Entities for Illegal Off-Exchange Trading and Registration Violations - On July 13, 2020, the Commodity Futures Trading Commission (CFTC) and...more

Proskauer - Blockchain and the Law

New York Proposes Conditional BitLicense Framework

The New York State Department of Financial Services (the “NYDFS”), as a part of a series of virtual currency initiatives, proposed in June a framework for applying for and obtaining a virtual currency Conditional BitLicense....more

Carlton Fields

State Regulations on Virtual Currency and Blockchain Technologies (Updated July 2020)

Carlton Fields on

There exists no uniformity with respect to how businesses that deal in virtual currencies (also known as "cryptocurrencies") such as Bitcoin are treated among the states. For these proprietors, often the first question asked...more

K&L Gates LLP

New York (More) Open for (Crypto) Business: NYDFS Proposes Important Changes to the BitLicense

K&L Gates LLP on

Since finalizing the “BitLicense” regulatory regime in June 2015, the New York Department of Financial Services (NYDFS) has granted only 25 licenses. This underscores how the BitLicense regulatory framework has been a barrier...more

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