Summary of New York Department of Financial Services Guidance on Virtual Currency Custodial Structures

On January 26, 2023, Cravath distributed a memo for its clients and other stakeholders entitled “Summary of New York Department of Financial Services Guidance on Virtual Currency Custodial Structures.” The memo examines an industry letter issued by the NYDFS, which provides guidance regarding virtual currency custody activities and is applicable to entities licensed under the state’s virtual currency regulations and limited purpose trust companies. The guidance clarifies standards and practices meant to ensure a high level of customer protection and reiterates existing expectations and requirements related to customer disclosures.

Please click here to read the memo.