AML in the Age of Cryptocurrency (Part 2)

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AML in the Age of Cryptocurrency (Part 1)

Introduction Virtual currency businesses get caught in the anti-money laundering (AML) web both coming and going.   Financial services businesses such as banks view them as suspect customers and suspect business partners, and either flee or impose stringent information requirements and onerous ongoing monitoring.  Meanwhile, the banks may be filing secret reports with the U.S. federal […]

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New York Cybersecurity Requirements for Banks and Financial Institutions

On March 1, 2017, the New York State Department of Financial Service’s (the “DFS”) final cybersecurity regulations became effective (see 23 NYCRR § 500). These rules were originally published on September 13, 2016. Just before the end of the year, the DFS published another proposed regulation that eased somewhat the requirements of the original proposal […]

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New York’s Banking Chief Challenges the Industry

In late February, the Superintendent of the New York State Department of Financial Services (the “DFS”) gave a speech at Columbia Law School on the role of state banking departments in the regulation of financial institutions.  New York State has been the capital of the banking industry in the United States since before any of […]

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