"BitLicensing": New York Virtual Currency Regulations Include Cybersecurity Program Requirement

On June 3, 2015, the New York Department of Financial Services ("NYDFS") issued its final virtual currency regulations after spending a year considering multiple proposals and thousands of comment letter submissions. Notably, the New York regulations include a requirement that businesses providing virtual currency services establish and maintain a cybersecurity program.

The New York regulations constitute the first comprehensive regulatory regime for virtual currency in the United States, although various American federal agencies have issued guidance and some other states have also proposed virtual currency legislation. In contrast, in Canada, there is currently no comprehensive regime to regulate virtual currencies. To date, regulatory developments in respect of virtual currencies in Canada have essentially been limited to anti-money laundering reforms (please see our blog post AMF Now Requires Quebec Virtual Currency ATMs and Trading Platforms to be Licensed for