NYDFS Launches A Series Of Virtual Currency Initiatives To Ease Market Entry

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Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The New York State Department of Financial Services launched a series of virtual currency initiatives aimed at easing market entry for start-ups and emerging companies.
United States Finance and Banking
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The New York State Department of Financial Services ("NYDFS") launched a series of virtual currency initiatives aimed at easing market entry for start-ups and emerging companies.

In the press release, the NYDFS announced:

  • a signed memorandum of understanding with the State University of New York ("SUNY") detailing their plan to launch a new SUNY-related virtual currency program, "SUNY BLOCK," intended to support emerging virtual currency entities from local communities;
  • a new conditional licensing framework that eases market entry for start-ups and emerging companies partnering with an existing entity authorized by NYDFS to engage in virtual currency business activity (such as the new SUNY BLOCK program);
  • final guidance that covers licensees' ability to self-certify the use of new coins, and outlines the approach by which NYDFS will provide a list of approved coins that all licensees can easily adopt;
  • a notice of NYDFS practices aimed at creating a more transparent and efficient process for the evaluation of virtual currency license applications; and
  • new virtual currency-related FAQs that will address questions identified through discussions with current and prospective market participants.

Comments on the proposed licensing framework must be submitted by August 10, 2020.

Primary Sources

  1. NYDFS Press Release: DFS Superintendent Lacewell Launches Series of Virtual Currency Initiatives
  2. NYDFS, SUNY Memorandum of Understanding
  3. NYDFS Request for Comments on a Proposed Framework for a Conditional BitLicense
  4. NYDFS Guidance: Regarding Adoption or Listing of Virtual Currencies
  5. NYDFS Notice; Virtual Currency Business Activity License Application Procedures
  6. NYDFS FAQ: BitLicense

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