On October 13, 2023, California Governor Gavin Newsom signed into law AB39, the Digital Financial Assets Law (the Act). The Act provides broad authority to California’s Department of Financial Protection and Innovation (Department) to license, regulate and examine certain businesses transacting in digital financial assets in California.
Continue Reading California Enacts Digital Financial Assets Law

On September 18, 2023, the New York Department of Financial Services (“DFS”) announced new proposed guidance for BitLicense holders and certain limited-purpose trust companies (“VC entities”) seeking to list virtual currencies on their platforms. The proposed guidance would replace existing DFS procedures and establish new protocols for listing virtual currencies that are not subject to the DFS greenlist.
Continue Reading New York DFS Announces New Guidance on Virtual Currencies

As reported in a Hunton Client Alert, the US Department of Justice, the US Department of Commerce’s Bureau of Industry and Security, and the US Department of the Treasury’s Office of Foreign Assets Control recently issued guidance regarding the voluntary self-disclosure by US businesses of violations of US sanctions and export control laws to these agencies.
Continue Reading DOJ, BIS, and OFAC Issue Inter-Agency Guidance on Voluntary Self-Disclosures of Sanctions and Export Control Violations

As reported in a Hunton Client Alert last week, on June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency issued final guidance on managing risks associated with third-party relationships, including relationships with fintechs.
Continue Reading Interagency Guidance for Bank Risk Management of Third-Party Relationships

On May 5, 2023, New York Attorney General Letitia James released proposed legislation that seeks to regulate all facets of the cryptocurrency industry. Entitled the “Crypto Regulation, Protection, Transparency, and Oversight (CRPTO) Act,” if enacted the draft bill would substantially expand New York’s oversight of crypto enterprises conducting business in the Empire State.
Continue Reading New York Attorney General Proposes Sweeping Crypto Legislation