Familiar Themes in DFS’s First Enforcement Action Against Virtual Currency Company

August 18, 2022  |  New York Law Journal

On August 2nd, the New York State Department of Financial Services announced a consent order with Robinhood Crypto, finding that they failed to maintain proper anti-money laundering and cybersecurity compliance programs, resulting in a $30 million fine and an 18-month review by an independent compliance consultant. In my latest article for the New York Law Journal, “Familiar Themes in DFS’s First Enforcement Action Against Virtual Currency Company,” I discuss how it behooves regulated businesses in this nascent industry to learn from the experiences of traditional financial institutions, and to ensure that risk-based compliance programs and transparent regulatory engagement are priorities that run in tandem with their business’s growth.

Familiar Themes in DFS’s First Enforcement Action Against Virtual Currency Company (pdf | 169.25 KB)