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ARTICLE · 05 MAY 2022

Analyze This: The NYDFS Sets Clear Crypto Transaction Monitoring Expectations

Morrison Foerster
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The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters.

United StatesTechnology
Marc-Alain Galeazzi
Marc-Alain Galeazzi
Barbara Mendelson
Barbara Mendelson
Jeremy Mandell
Jeremy Mandell
Tessa Schwartz
Tessa Schwartz
Malka Levitin
Malka Levitin
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The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters. For example, in November 2021, the President's Working Group on Financial Markets, along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a long-awaited Report on Stablecoins, recommending comprehensive federal legislation for stablecoins. In December 2021, the federal banking agencies released a statement announcing the establishment of "crypto-asset policy sprints," to generate coordinated guidance from the agencies.1 And in March 2022, President Biden signed an Executive Order calling on federal agencies to take a unified approach to regulating and overseeing digital assets. But while the industry still awaits comprehensive federal regulation, the New York Department of Financial Services (DFS) has moved forward

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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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