According to a stipulation filed (1822000-1822445-stipulation) in the BlockFi bankruptcy proceeding in New Jersey:
• NYDFS had asserted unliquidated claims for violation of Financial Services Law § 408, one of its omnibus enforcement authorities, and the BitLicense Regulation, 23 N.Y.C.R.R. Part 200
• BlockFi does not appear to have ever obtained a license or charter from NYDFS. That suggests the unliquidated claims were filed for allegedly operating a virtual currency business in New York without a NYDFS license.
• NYDFS took this step, permitting most of its claims to be erased from the bankruptcy proceeding and others to be moved back in priority, “in order to maximize the amount that may be distributed to BlockFi consumer clients, including those who are residents of New York state.”