Cryptoassets Regulatory Intelligence cryptoassets.gi
US-NY v13.3.0
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United States — New York

US-NY schema crypto-v2.0.0 trajectory: not yet assessedregulatedoverlaps: FIM, WPM

Last updated · 7 categories · 34 sourced findings · 13 sources in the cumulative register

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34Findings.claims[]
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Jurisdiction lead brief

Lead Signal

On June 9, 2026, the New York State Department of Financial Services proposed new 23 NYCRR Part 202, a rule intended to bring the state's stablecoin supervisory framework into alignment with the federal GENIUS Act. The proposal is now in a two-stage public comment process -- a 10-day preproposal window followed by a 60-day comment period -- and DFS has structured the transition deliberately: its existing June 2022 stablecoin guidance, which has governed authorized U.S.-dollar-backed stablecoin issuance in New York for four years, remains the binding standard until Part 202 takes effect, and that effective date is itself tied to when the GENIUS Act becomes operative at the federal level, with a further one-year transition window built in for issuers already operating under the 2022 framework. Substantively, the draft introduces thresholds not present in the 2022 guidance: issuers with $25 billion or more in outstanding stablecoins would need to hold at least 0.5% of reserves (capped at $500 million) in insured deposits, concentration limits would cap how much reserve exposure any single custodian could hold, and a wind-down mechanism -- full, fee-free redemption -- would trigger automatically if an issuer's reserves fell below the required minimum for 15 consecutive business days. This is best read as codification-plus-tightening rather than a wholesale regime change: the core architecture DFS built in 2022 -- 1:1 segregated reserve backing, T+2 redemption rights, monthly independent attestation, and a standing refusal to approve algorithmic stablecoin designs following the 2022 TerraUSD collapse -- carries forward largely intact, with Part 202 adding federal-alignment machinery and explicit stress-scenario triggers on top of it. The comment period is expected to close in the third quarter of 2026, after which DFS may move toward finalization; issuers currently operating under the 2022 guidance should expect the terms of the eventual transition period to be a live point of industry comment.

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#

New York's licensing regime remains stable and long-established: the dual-track BitLicense/LPTC model (23 NYCRR Part 200; NY Banking Law) has been fully in force since 2015, with a clear activity-based trigger (200.2(q)), narrow merchant/consumer and mining carve-outs, and prudential bonding/capitalization floors. The only structural addition identified this cycle is the Part 102 assessment-billing regime (adopted April 2023, implementing 2022-amended FSL Section 206(a)), a cost-recovery mechanism rather than a change to licensing scope.

Standing sub-brief580 words · last cycle 2026-08-25

Crypto Licensing

New York operates the most mature dual-track virtual currency licensing regime in the United States, built around 23 NYCRR Part 200's BitLicense requirement and, as an alternative entry point, the limited-purpose trust company (LPTC) charter under the state Banking Law. Under 23 NYCRR 200.2(q), a BitLicense is required for anyone conducting Virtual Currency Business Activity in or with New York -- receiving or transmitting virtual currency, providing custody, buying or selling virtual currency as a customer business, providing exchange services, or controlling, administering, or issuing virtual currency. This activity-based trigger, in force since 2015, remains the operative perimeter test for the regime, and DFS has not revised its core scope this cycle.

Periodic update · new data 2026-08-26

Crypto Licensing

New York's BitLicense regime, codified at 23 NYCRR Part 200, together with the limited-purpose trust company charter option under the New York Banking Law, remains the operative gateway for Virtual Currency Business Activity in the state, a requirement unchanged since it took effect in June 2015. NYDFS continued to enforce that perimeter in early 2026, issuing cease-and-desist orders and civil penalties, reported at between $100,000 and $500,000, against three cryptocurrency platforms found to be serving New York residents without BitLicenses. That specific enforcement finding is sourced to a single Tier 4 vendor summary and has not yet been corroborated against a primary NYDFS release, so it is carried here as a continuation signal rather than a fully confirmed new enforcement wave, though it is consistent with a regime that has fewer than fifty BitLicense holders as of 2026 and a long track record of pursuing unlicensed operators.

The regime's near-term risk profile is shaped less by the licensing framework itself, which is mature and largely unchanged, than by an adjacent and unresolved legal question: the New York Attorney General's suit against Coinbase and Gemini's prediction-market products asserts a gambling-law theory that, if sustained, would sit alongside or intersect with the BitLicense perimeter for crypto-exchange-hosted products. That dispute is not itself a BitLicense enforcement action, but it is relevant context for any BitLicense holder or applicant assessing New York's overall regulatory posture toward exchange-hosted novel product categories this cycle.

Outlook

Independent corroboration of the three-platform cease-and-desist action, beyond the current single-source vendor summary, is the main sourcing gap to close for this module. The outcome of the Attorney General's prediction-market litigation against Coinbase and Gemini, while formally a consumer-protection and gambling-law matter, is also the item most likely to reshape how BitLicense holders assess exchange-hosted novel product risk going forward.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (6)
  1. T1 · NY Department of Financial ServicesNYDFS BitLicense regime (23 NYCRR 200.2(q)) — Virtual Currency Business Activity in or with New York -- receiving/transmitting VC, custody, buying/selling as customer business, exchange services, or controlling/administering/issuing VC -- requires a BitLicense.retrieved M5bindingin forcenew
  2. T1 · NY Department of Financial ServicesNY limited purpose trust company (LPTC) charter — As an alternative to the BitLicense, a NY LPTC charter under the NY Banking Law permits money transmission without a separate MTL and confers fiduciary powers unavailable to BitLicensees.retrieved M4bindingin forcenew
  3. T1 · NY Department of Financial Services23 NYCRR 200.3(c) exemption — Merchants/consumers using VC solely to buy/sell goods or services, and consumers using VC solely for investment, are exempt from the BitLicense requirement.retrieved M3bindingin forcenew
  4. T1 · NY Department of Financial ServicesVirtual currency mining / private resale — Mining and private, non-commercial resale of self-mined coins do not in themselves require a BitLicense; other VC activities a miner separately engages in may trigger licensure.retrieved M2non-bindingnew
  5. T1 · NY Department of Financial Services23 NYCRR 200.9(a) / 200.8 — BitLicensees must maintain a surety bond or funded account (generally minimum $500,000, may increase) for customer protection; separate capitalization requirements are set under 200.8.retrieved M4bindingin forcenew
  6. T1 · NY Department of Financial Services23 NYCRR Part 102 / FSL Section 206(a) — NYDFS assesses licensed VC businesses for supervision/examination costs via quarterly estimated billings trued up against actual Virtual Currency Unit expenses, under Part 102 (adopted April 2023) implementing 2022-amended FSL Section 206(a).retrieved M3bindingin forcenew

#

No dedicated NY statutory taxonomy exists for tokens; classification is functionally driven by DFS's discretionary Greenlist/coin-listing process (Nov 2023), which restricts self-certification for entities without an approved policy and treats stablecoins as a distinct listing category. An unresolved federal securities-preemption argument raised by a private issuer's SEC filing remains unconfirmed by DFS.

Standing sub-brief384 words · last cycle 2026-08-25

Token Classification

New York has no dedicated statutory taxonomy for classifying tokens; in practice, classification functions through DFS's discretionary coin-listing regime. Under the November 2023 industry letter establishing the Greenlist and coin-listing framework, a virtual currency entity that has not obtained a DFS-approved coin-listing policy may list only coins on the Greenlist, while an entity with an approved policy may self-certify other coins against DFS's compliance criteria -- but DFS retains sole discretion to require delisting of any coin at any time, regardless of how it was listed. This is a supervisory gatekeeping mechanism rather than a legal classification test, and it operates independently of, though alongside, whatever separate securities-law analysis might apply to a given token federally.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (3)
  1. T2 · NY Department of Financial ServicesNYDFS Greenlist / coin-listing policy — VC Entities without a DFS-approved coin-listing policy may list only Greenlist coins; entities with an approved policy may self-certify other compliant coins, subject to DFS's sole discretion to require delisting at any time.retrieved M4bindingin forcenew
  2. T2 · NY Department of Financial ServicesDFS coin-listing guidance -- stablecoin category — Stablecoins are a distinct listing category: a VC Entity cannot self-certify any stablecoin absent Greenlist inclusion or separate prior written DFS approval.retrieved M4bindingin forcenew
  3. T3 · U.S. Securities and Exchange Commission (EDGAR filing)YouNow, Inc. Form 1-A POS disclosure — A private-party disclosure argues the BitLicense framework is preempted under Securities Act Section 18 (and NY FSL's federal/other-state carve-out) for tokens sold as 'covered securities'; NYDFS has not adopted or confirmed this position.retrieved M2non-bindingnew

#

No activity-specific staking/DeFi/DEX rulebook exists; staking is treated as a material change to business under 200.10, and DFS's Sept 2025 custody guidance expressly states it does not address staking or on-chain governance in detail. Mining remains outside the licensing perimeter, and no DeFi/DEX-specific framework has been identified.

Standing sub-brief375 words · last cycle 2026-08-25

On-Chain Activity Regime

New York has not published an activity-specific regulatory framework for staking, DeFi lending, or decentralized exchange operation, and the record this cycle underscores that this is a deliberate, regulator-acknowledged scope gap rather than an oversight on the research side. DFS's updated September 2025 custodial-structures guidance states directly that it addresses custodial safekeeping generally and is "not intended to address in detail" ancillary activities such as staking or on-chain governance -- meaning the entity most likely to have spoken to these activities has expressly declined to do so in its most recent, most relevant guidance document.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (4)
  1. T2 · NY Department of Financial ServicesNYDFS custodial-structures guidance (Sept 2025) — DFS's custodial-structures guidance expressly states it pertains to custodial safekeeping generally and is not intended to address in detail ancillary activities such as staking or on-chain governance.retrieved M3non-bindingnew
  2. T2 · NY Department of Financial Services23 NYCRR 200.10 (material change to business) — Introduction of a materially new product/service/activity by a VC Entity or LPTC, including offering staking, requires prior written DFS approval as a material change to business under 200.10.retrieved M4bindingin forcenew
  3. T1 · NY Department of Financial ServicesVirtual currency mining — Virtual currency mining does not in itself require a BitLicense in New York.retrieved M2non-bindingnew
  4. T1 · NY Department of Financial ServicesDeFi lending / DEX operation — No NYDFS-published activity-specific regulatory framework for DeFi lending or DEX operation has been identified.retrieved M2non-bindingnew

#

Core stablecoin guidance (June 2022) -- prior-approval issuance, 1:1 segregated reserves, T+2 redemption, monthly attestation, no algorithmic stablecoin approval -- remains the binding baseline. The lead development this cycle is DFS's June 2026 proposal of new 23 NYCRR Part 202 to align this framework with the federal GENIUS Act, adding reserve-concentration caps and wind-down triggers; the 2022 guidance is withdrawn only upon Part 202's effective date, with a one-year transition for existing issuers.

Horizon · 2026-Q3 (±quarter)Public comment period for proposed 23 NYCRR Part 202 (stablecoin issuer rule) expected to closeconsultation · T
Standing sub-brief477 words · last cycle 2026-08-25

Stablecoin Regime

New York's stablecoin framework is mid-transition. The operative baseline remains DFS's June 2022 guidance on the issuance of U.S. dollar-backed stablecoins, which requires any BitLicensee or LPTC to obtain DFS's prior written approval before introducing a stablecoin, treating issuance as a material change to business. That guidance builds a comprehensive prudential structure: an approved stablecoin must be fully backed 1:1 by a reserve held in segregated accounts at FDIC-insured institutions and/or DFS-approved custodians, composed only of a specified set of low-risk assets; issuers must adopt DFS-approved redemption policies giving holders a right to redeem generally within two business days, with delay permitted only where DFS allows it in extraordinary circumstances; and issuers must undergo at least monthly independent CPA attestation of reserve composition and outstanding-unit value, historically with bi-monthly public reporting, plus DFS-required bi-weekly reporting on bank-partnership relationships, reserve composition, and mint/burn flows. DFS has also drawn a clear supervisory line between fiat-collateralized designs, which it has approved, and algorithmic stablecoin designs, which it has not -- a distinction the 2022 guidance itself frames as informed by the 2022 TerraUSD collapse.

Periodic update · new data 2026-08-26

Stablecoin Regime

New York's stablecoin oversight regime is in a defined but not-yet-finalized transition. The standing framework, DFS's June 2022 Guidance on the Issuance of U.S. Dollar-Backed Stablecoins, requires DFS-regulated USD-backed stablecoin issuers to maintain reserves whose market value is at least equal to the nominal value of all outstanding stablecoin units as of each business day's end, verified monthly by an independent CPA under AICPA attestation standards; this requirement is unchanged this cycle and remains in force. What has moved this cycle is DFS's rulemaking process to align that guidance with the federal GENIUS Act's state-certification pathway. The resulting regulation is expected to take effect alongside the GENIUS Act on January 18, 2027, with a one-year transition period for existing New York-licensed stablecoin issuers, giving the market a defined, though still-provisional, compliance horizon.

This is a materially significant development for the stablecoin module because it will determine whether New York's existing reserve, redemption, and attestation framework carries over largely intact into the federally-certified era, or is substantively rewritten to match GENIUS Act requirements. Until the rulemaking is finalized, existing NY-licensed issuers continue to operate under the 2022 guidance, and the one-year transition period provides a defined runway once the new rule is adopted.

Outlook

The rulemaking's progress toward a finalized, GENIUS Act-aligned regulation, and the specific terms of the one-year transition period for existing issuers, are the key items to track ahead of the January 18, 2027 effective date.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (7)
  1. T2 · NY Department of Financial ServicesNYDFS stablecoin guidance (2022) — BitLicensees and LPTCs must obtain DFS's prior written approval before introducing a stablecoin, as issuance constitutes a material change to business.retrieved M5bindingin forcenew
  2. T2 · NY Department of Financial ServicesNYDFS stablecoin guidance (2022) -- reserve requirement — A DFS-approved USD-backed stablecoin must be fully backed 1:1 by a Reserve held in segregated accounts at FDIC-insured institutions and/or DFS-approved custodians, composed only of specified low-risk assets.retrieved M5bindingin forcenew
  3. T2 · NY Department of Financial ServicesNYDFS stablecoin guidance (2022) -- redemption — Issuers must adopt DFS-approved redemption policies conferring holder redemption rights fulfilled generally within two business days (T+2), except where DFS permits delay in extraordinary circumstances.retrieved M5bindingin forcenew
  4. T2 · NY Department of Financial ServicesNYDFS stablecoin guidance (2022) -- attestation/reporting — Issuers must undergo at least monthly independent CPA attestation of Reserve composition/outstanding-unit value, with historically bi-monthly public reporting, plus DFS-required bi-weekly reporting of bank-partnership relationships, reserve mix, and mint/burn flows.retrieved M4bindingin forcenew
  5. T1 · NY Department of Financial ServicesProposed 23 NYCRR Part 202 (Authorized Payment Stablecoin Issuers) — On June 9, 2026 NYDFS proposed new 23 NYCRR Part 202 to align its stablecoin framework with the federal GENIUS Act; subject to a 10-day preproposal comment period followed by a 60-day comment period; the 2022 guidance is withdrawn only upon Part 202's effective date, tied to GENIUS Act operativeness with a one-year transition for existing issuers.retrieved M5bindingproposednew
  6. T1 · NY Department of Financial ServicesProposed 23 NYCRR Part 202 -- reserve concentration/wind-down — Issuers with >=$25B outstanding stablecoins would hold >=0.5% of reserves (capped at $500M) in insured deposits, cap reserve concentration at any single custodian, and mandate wind-down (liquidation, fee-free redemption) if minimum reserves unmet for 15 consecutive business days.retrieved M4bindingproposednew
  7. T2 · NY Department of Financial ServicesNYDFS algorithmic-stablecoin policy — NYDFS has not approved issuance of any algorithmic stablecoin, reflecting a supervisory policy distinguishing fiat-collateralized issuance (approved) from algorithmic designs (not approved), informed by the 2022 TerraUSD collapse.retrieved M3bindingin forcenew

#

Binding, enforced custody-segregation, disclosure, and anti-deceptive-marketing rules are well documented under 23 NYCRR Part 200, recently reinforced by the Sept 30 2025 updated custodial-structures guidance covering segregation, sub-custodian disclosure, and insolvency-protection standards. Suitability testing and dedicated complaint-handling rules remain gaps.

Standing sub-brief428 words · last cycle 2026-08-25

Consumer Protection

New York's consumer protection framework for virtual currency businesses rests on three pillars: asset protection and disclosure obligations under 23 NYCRR Part 200, detailed custodial-segregation requirements reinforced by DFS's September 2025 guidance, and a standing prohibition on deceptive marketing. Under Part 200, BitLicensees must hold virtual currency in a manner that protects customer assets, maintain comprehensive books and records, and properly disclose the material terms of their products and services, including custody arrangements.

Periodic update · new data 2026-08-26

Consumer Protection

NYDFS's custody-segregation requirement, under which regulated virtual currency custodians must separately account for and segregate customer virtual currency from corporate and other non-customer assets on-chain and on internal ledgers, remains the settled backbone of New York's crypto consumer-protection regime and is unchanged this cycle. What is new is a distinct, adjacent development: the New York Attorney General's April 2026 suit against Coinbase and Gemini alleges that the platforms' prediction-market products exposed users, including those under the state's twenty-one-year gambling age minimum, to unregulated wagering risk without the consumer protections gambling law would otherwise require. This is a non-binding litigation development, not a settled custody or disclosure rule, and it sits at the boundary between crypto consumer-protection and gambling-law enforcement rather than squarely within DFS's BitLicense custody framework.

The distinction matters for how operators should read this cycle's signal: the custody-segregation rules that anchor this module remain settled and binding for any BitLicense holder, while the prediction-market consumer-protection theory is contested and unresolved, dependent on the outcome of active litigation rather than an existing statute or regulation.

Outlook

The outcome of the Attorney General's suit against Coinbase and Gemini is the principal item to watch for this module, since a ruling either way would clarify whether prediction-market products hosted by crypto exchanges are read as falling within New York's consumer-protection and gambling-law framework.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (7)
  1. T2 · NY Department of Financial Services23 NYCRR Part 200 -- asset protection/disclosure — BitLicensees must hold VC in a manner that protects customer assets, maintain comprehensive books/records, and properly disclose material terms of products/services including custody.retrieved M5bindingin forcenew
  2. T2 · NY Department of Financial ServicesNYDFS custodial-structures guidance (Sept 2025) -- segregation detail — VCE Custodians must separately account for and segregate customer VC from corporate assets on-chain and on internal ledgers via individually named wallets/ledger accounts or omnibus accounts held as agent/trustee with a clear audit trail; exceptions require DFS prior written approval.retrieved M5bindingin forcenew
  3. T2 · NY Department of Financial Services23 NYCRR Part 200 -- marketing restriction — BitLicensees must refrain from false, misleading, or deceptive representations or omissions in marketing materials.retrieved M4bindingin forcenew
  4. T2 · NY Department of Financial ServicesVCE Custodian disclosure expectations — A VCE Custodian is expected to clearly disclose segregation/accounting methods, the customer's retained property interest, permitted uses of custodied VC, and applicable limitations, and make standard disclosures/customer agreements accessible on its website.retrieved M4bindingin forcenew
  5. T2 · NY Department of Financial ServicesSub-custody disclosure requirement — Where a VCE Custodian uses third-party sub-custody, the customer agreement must disclose the arrangement's terms/risks, and the sub-custodian must be DFS-chartered/licensed or subject to a substantially similar regime as determined by DFS's sole discretion.retrieved M4bindingin forcenew
  6. T1 · NY Department of Financial ServicesSuitability/appropriateness testing — No NYDFS-specific suitability or appropriateness-testing regime for retail virtual currency product offerings was identified.retrieved M2non-bindingnew
  7. T1 · NY Department of Financial ServicesComplaint-handling rulebook — No dedicated public complaint-handling rulebook specific to virtual currency consumers was located beyond general DFS supervisory-agreement/consumer-assistance mechanisms.retrieved M2non-bindingnew

#

Long-standing Dec 2014 property-tax conformance memorandum (secondary-sourced) remains the operative NY position: VC purchases not subject to sales tax (intangible property/barter treatment); income tax conforms to IRS Notice 2014-21 property treatment. No material update identified, and the primary source itself remains unretrieved.

Standing sub-brief230 words · last cycle 2026-08-25

Tax Treatment

New York's tax treatment of virtual currency traces to a single December 2014 memorandum from the state Department of Taxation and Finance, which treats virtual currency purchases as not themselves subject to New York sales tax because virtual currency is treated as intangible property; a sale or exchange involving virtual currency is instead characterized as a barter transaction, meaning only the goods or services exchanged for virtual currency -- not the virtual currency itself -- are subject to sales tax and related reporting. New York's income tax treatment, both corporate and personal, conforms to the federal property-characterization approach the IRS set out in Notice 2014-21. No New York-specific virtual-currency information-reporting obligation distinct from federal IRS reporting requirements has been identified.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (3)
  1. T4 · CoinDesk (reporting on NY Dept. of Taxation and Finance memorandum)NY Dept. of Taxation and Finance (Dec. 2014 memorandum) — Virtual currency purchases are not themselves subject to NY sales tax because VC is treated as intangible property; sale/exchange involving VC is a barter transaction, so only certain goods/services exchanged for VC are subject to sales tax/related reporting.retrieved M3bindingin forcenew
  2. T4 · CoinDesk (reporting on NY Dept. of Taxation and Finance memorandum)NY income tax conformity — NY corporate/personal income tax treatment of digital currency conforms to federal (IRS) property treatment per IRS Notice 2014-21 principles.retrieved M3bindingin forcenew
  3. T4 · CoinDesk (reporting on NY Dept. of Taxation and Finance memorandum)NY-specific VC information-reporting obligation — No New York-specific virtual-currency information-reporting obligation distinct from federal IRS reporting requirements was identified in this research pass.retrieved M2non-bindingnew

#

NYDFS has reiterated OFAC sanctions-screening and blockchain-analytics expectations for cross-border/on-chain flows via the June 2025 Industry Letter on global-conflict risk, building on April 2022 blockchain-analytics guidance. No NY-specific outbound capital-flow restriction distinct from federal OFAC programs was identified; this module captures only the sanctions-screening slice, with the broader AML/CFT surface subscribed to financial-integrity pending A1 consolidation.

Standing sub-brief349 words · last cycle 2026-08-25

Cross-Border Transfer

New York's cross-border-transfer-relevant obligations for virtual currency businesses are concentrated in sanctions compliance and on-chain transaction monitoring, both layered onto the state licensing regime as extensions of federal OFAC obligations rather than as freestanding state-level capital-flow controls. DFS's June 2025 industry letter on the impact of ongoing global conflicts reiterates that DFS-regulated entities, including virtual currency businesses, are prohibited from transacting with OFAC SDN-listed persons absent authorization, and must monitor for and block sanctioned transactions while continuously updating their compliance policies. The same letter sets out DFS's expected internal controls: geolocation and IP-based identification and blocking, and blockchain analytics and transaction monitoring capable of identifying virtual currency addresses linked to SDN-listed persons or to comprehensively sanctioned jurisdictions.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (4)
  1. T2 · NY Department of Financial ServicesNYDFS Industry Letter -- Impact of Global Conflict (June 2025) — NYDFS-regulated entities, including VC businesses, are prohibited from transacting with OFAC SDN-listed persons absent authorization, and must monitor for/block sanctioned transactions, continuously updating compliance policies.retrieved M5bindingin forcenew
  2. T2 · NY Department of Financial ServicesDFS sanctions-control expectations (June 2025 letter) — Expected internal controls include geolocation/IP identification and blocking, and blockchain analytics/transaction monitoring to identify VC addresses linked to SDN-listed persons or comprehensively sanctioned jurisdictions.retrieved M4bindingin forcenew
  3. T2 · NY Department of Financial ServicesNYDFS blockchain-analytics guidance (April 2022) — VC Entities must conduct sanctions screening of on-chain activity and provenance/transaction tracing for inbound/outbound flows across each supported VC, given the pseudonymous, peer-to-peer nature of on-chain transfers.retrieved M4bindingin forcenew
  4. T2 · NY Department of Financial ServicesNY-specific outbound capital-flow restriction — No New York-specific outbound capital-flow restriction on virtual currency transfers (distinct from federal OFAC sanctions programs) was identified.retrieved M2non-bindingnew
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