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Financial Services Law Insights and Observations

NYDFS issues first “conditional Bitlicense”

State Issues Digital Assets NYDFS Fintech Cryptocurrency

State Issues

On October 21, NYDFS announced authorization for a digital payments company to launch a service for U.S. customers to buy, sell, and hold certain NYDFS-approved cryptocurrencies. Under the terms of the “conditional Bitlicense,” the payments company will partner with a New York-chartered trust company responsible for providing cryptocurrency trading and custodial services. According to NYDFS Superintendent Linda Lacewell, this first conditional Bitlicense represents the state regulator’s efforts “to encourage, promote, and assist interested institutions to have a well-regulated way to access the New York virtual currency marketplace in a way that is both timely and protective of New York consumers.” NYDFS first announced the proposed conditional licensing framework in June (covered by InfoBytes here).