ACTING SUPERINTENDENT ASROW ISSUES NYDFS CONSENT ORDER PENALIZING PURPORTED HEALTH CARE SHARING MINISTRY $250,000 AND ORDERS IT TO CEASE OPERATIONS

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According to a New York State Department of Financial Services press release under Acting Superintendent Kaitlin Asrow: ·       House of Prayer and Life, Inc. d/b/a Jericho Share or Jericho Health Share purported to act as a federally-authorized Health Care Sharing Ministry. ·       Instead of properly qualifying under that federal law, DFS found Jericho had operated as an … Read more

OCC GRANTS CONDITIONAL TRUST CHARTERS TO CIRCLE, RIPPLE, PAXOS, BIGTO AND FIDELITY

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Reports Forbes: “OCC trust bank charters for Circle, Ripple, Paxos, BitGo and Fidelity Digital Assets are one of the clearest signals yet that crypto is moving from the regulatory perimeter into the core of the U.S. banking system. For banks, it is arguably the biggest institutional crypto signal of 2025—just as spot bitcoin ETFs were … Read more

NYDFS ACTING SUPERINTENDENT KAITLIN ASROW SPEAKS TO PHILIDELPHIA FED FINTECH CONFERENCE RE: CYRPTO, AI, THIRD PARTY RISK MANAGEMENT AND BNPL

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In a fireside chat with Penny Lee, President and CEO, Financial Technology Association, Acting Superintendent Kaitlin Asrow discussed: ·       Crypto: given the changing regulatory environment at the federal level, Superintendent Asrow believes some DFS charters will flip to federal; some entities will want to hold both federal and state charters; and some entities will hold onto DFS … Read more

NYDFS COMPLETES CYBERSECURITY INVESTIGATION SWEEP WITH ENFORCEMENT ACTIONS AGAINST MULTIPLE INSURANCE COMPANIES

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Superintendent Harris has been busy on her way out the door: – In addition to issuing several pieces of guidance in the past few weeks, she announced Consent Orders with 8 insurance firms and brokers resolving an investigation involving attacks on agent and consumer portals that allegedly exposed consumer information. According to the DFS press … Read more

NYDFS ISSUES GUIDANCE ON OBTAINING A “NOTICE OF SATISFACTION OF AGREEMENTS”

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NYDFS issued guidance in the form of a policy statement on obtaining what it terms a “Notice of Satisfaction of Agreements.” ·       Importantly, a Satisfaction Notice does not serve as the termination of a Consent Order, Written Agreement or MOU: “Notices will not alter, rescind, or seal an Agreement, and they will not cancel any restriction imposed … Read more

NYDFS ISSUES GUIDANCE FOR BANKS REGARDING BLOCKCHAIN RISKS

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NYDFS issued guidance for regulated banking institutions concerning their approach to risks associated with cryptocurrency businesses that may be bank customers or that interact with bank customers ·       The guidance sensibly responds to the more permissive regulatory environment for cryptocurrency filtering down from the Trump Administration’s major policy shifts ·       The guidance principally relates to the use … Read more

NYDFS JOINS MULTISTATE ACTION AGAINST MONEY TRANSMITTER WISE WITH $4.2 MM PENALTY

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According to the Consent Order: •        Multistate examination found AML deficiencies  including (a) failure to provide for an independent review of the AML Program on a frequency commensurate with services provided; (b) deficiencies identified in processes for investigating and reporting suspicious activity, including the failure to timely file SARs; (c) transaction monitoring data integrity issues; (d) … Read more

NYDFS SUPERINTENDENT HARRIS AND DEPUTY SUPERINTENDENT COGHILL TALK CRYPTO REGULATION AT CONSENSUS 2025

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Some takeaways: •  On the BitLicense generally: o  Harris: New York has an outsized role to play; the BitLicense framework remains a model for the U.S. and the world o  Coghill: DFS has been very careful to uphold standard, that is very why most entities do not make it through the application process •     On the Application Process: o  Harris: Team of 60 … Read more