On June 24, 2020, the New York State Department of Financial Services ("NYDFS") announced a series of initiatives designed to provide further guidance and resources for businesses operating in, and potential new entrants into, the virtual currency industry. The initiatives represent the first major update to NYDFS' "BitLicense" – the regulatory regime set up in 2015 that governs virtual currency activity involving New York residents and companies, including a proposed conditional licensing framework intended to authorize entities without a BitLicense to engage in virtual currency business in New York under a conditional license.
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A special thanks to Amani Carter for her contributions to this client alert.
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