On Sept. 18, 2023, the New York State Department of Financial Services (NYDFS) issued a press release announcing updates to its ongoing oversight of the digital asset space, including (1) industry guidance regarding a “General Framework for Greenlisted Coins” (Greenlist Guidance); (2) industry guidance regarding new “Proposed Updates to Guidance Regarding Listing of Virtual Currencies” (Proposed Updated Listing Guidance); and (3) an updated list of “Greenlisted Coins” (the Greenlist).

Continue reading the full GT Alert.

Tags: banking and financial services, blockchain, Financial Regulatory Compliance, GT Insight, NYDFS
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of William Mack William Mack

William B. Mack is a co-chair of the Financial Regulatory & Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority

…

William B. Mack is a co-chair of the Financial Regulatory & Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority (FINRA) rules.

William’s practice involves all aspects of broker-dealer regulation, including Self-Regulatory Organization (SRO) membership, supervision, employment, research, soft dollar arrangements, chaperoning of foreign broker-dealers, social media, use of foreign finders, anti-money laundering rules, alternative trading systems (ATS), exchanges, and market making issues. He also provides regulatory guidance to investment banking clients in connection with securities offerings and related trading issues.

William advises firms in the FINRA new membership (NMA) and the continuing membership (CMA) processes. William assists firms to develop or amend their written supervisory procedures and compliance manuals.

William routinely represents clients who are negotiating placement agent agreements, foreign finders agreements, clearing agreements, agreements with registered representatives and expense-sharing agreements.

William assists broker-dealers and their associated persons to respond to regulatory examinations and inquiries and provides effective representation in a range of enforcement proceedings with the SEC, FINRA, NYSE, state and foreign regulatory authorities. He regularly prepares and defends witnesses in FINRA on-the-record interviews and SEC testimony. Enforcement matters have involved issues including market manipulation, supervision, customer defalcations, insider trading, anti-money laundering, distribution of unregistered securities, direct market access, market making, soft dollar arrangements, cross border trading, electronic intrusion and customer impersonation, sales practices, supervision, private placements, ETFs, indexes, and other securities products.

William regularly addresses questions with respect to what activities require or are exempt from broker-dealer registration. William assists firms in obtaining guidance, interpretive letters, and no-action relief from FINRA and the SEC with respect to novel securities issues and the creation of new products and services. William also advises clients on cryptocurrency, tokenization, NFTs, DeFi structures, and digital asset exchanges and trading.

Prior to joining the firm, William was a Principal Counsel for Enforcement at FINRA. Before FINRA, he was the Director of the Executive Secretariat in the Office of the U.S. Trade Representative. William also served as a Deputy Associate Counsel at the White House, advising primarily on appointments and investigations. Before the White House, he practiced at large firms in New York. William clerked for Judge Robert L. Carter in the Southern District of New York.

Read more about William Mack
Show more Show less
Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

Read more about Marina Olman-Pal
Show more Show less
Photo of Steven T. Cummings Steven T. Cummings

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial…

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial Services, Steven supervised the virtual currency team in evaluating virtual currency applications for regulatory compliance with anti-money laundering, cybersecurity, and consumer protection requirements.

Read more about Steven T. CummingsSteven's Linkedin Profile
Show more Show less
Related Posts
Bitcoin over a microprocessor in a motherboard-Shutterstock_1985279114
New York’s Proposed Moratorium on Cryptocurrency Mining Operations
June 23, 2022
New York State Capitol Building, Albany
NYDFS Becomes First US Financial Regulator to Issue Stablecoin Expectations to Virtual Currency Industry
June 22, 2022
shutterstock_735743386 (1)
DOJ’s Cryptocurrency Framework: A New Perspective?
October 14, 2020