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Jessica Carey, Roberto Gonzalez and Carly Lagrotteria Discuss New York DFS' First Crypto Enforcement Action in Law360 Column

September 6, 2022

Litigation partners Jessica Carey and Roberto Gonzalez and associate Carly Lagrotteria discuss key takeaways from the New York Department of Financial Services’ (DFS) first enforcement action against a crypto company in a column published in Law360 on September 6. Given the DFS’ current focus on compliance programs, leadership and culture, the authors note, crypto companies should continually evaluate their compliance programs to keep pace with their product offerings, market developments and regulatory expectations.

The $30 million consent order, announced on August 2, appears to signal that “DFS will continue to focus on areas — such as resourcing — that have been the subject of numerous prior enforcement actions involving traditional financial services companies,” the authors note. “Further, this order suggests that regulators are continuing to focus on enforcing AML and cybersecurity laws relating to digital assets.”

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