New York Proposes Conditional BitLicense: Conditional License Framework Would Allow Entities Without a BitLicense to Engage in Virtual Currency Business Activity in Collaboration with BitLicensees; NYDFS Requests Public Comments

Sullivan & Cromwell LLP - June 30, 2020

On June 24, 2020, the New York State Department of Financial Services proposed a framework to authorize entities without a BitLicense or a trust company charter to engage in virtual currency business activities in New York under a conditional license. The proposed framework would allow these entities to engage in virtual currency business activity in collaboration with an authorized BitLicensee or a holder of a New York limited purpose trust charter. Under the proposed framework, such conditionally licensed entities would engage with fully licensed entities to receive services and support, such as those relating to structure, capital, systems or personnel. NYDFS has requested comments on the proposed framework by August 10, 2020.