What New York State Department of Financial Services - Virtual Currency Business Licensing (BitLicense) under 23 NYCRR Part 200 (Issued June 2015 under the New York Financial Services Law); Plus Alternative Limited Purpose Trust Company Charter Pathway under New York Banking Law requires
The New York State Department of Financial Services (DFS) administers the foundational US state-level virtual currency business licensing regime under 23 NYCRR Part 200 (the BitLicense regulation), which was issued in June 2015 under the New York Financial Services Law. The BitLicense regime is the longest-standing comprehensive US state-level virtual currency licensing framework and remains the operative starting point for any entity intending to conduct virtual currency business activity in New York State. To conduct virtual currency business activity in NYS, entities can either apply for a BitLicense under 23 NYCRR Part 200 OR apply for a charter under the New York Banking Law (typically as a New York State limited purpose trust company or New York State bank with approval to conduct virtual currency business). The two pathways are similar but the limited purpose trust company charter offers additional benefits: (i) a limited purpose trust company can exercise fiduciary powers, while a BitLicensee cannot; and (ii) a limited purpose trust company can engage in money transmission in New York without obtaining a separate New York money transmitter license. The BitLicense application is managed via NMLS (Nationwide Multistate Licensing System and Registry, operated by the Conference of State Bank Supervisors with the American Association of Residential Mortgage Regulators) and follows the BitLicense Application Checklist; failure to submit complete documentation is the most common reason for application delays. NYDFS supervisory expectations are operationalised through industry letters, including guidance on the issuance of US dollar-backed stablecoins (June 2022), use of blockchain analytics (April 2022), listing of virtual currencies (November 2023), the general framework for greenlisted coins (September 2023), custodial structures for customer protection in insolvency (most recently updated September 2025, superseding January 2023 guidance), prevention of market manipulation and other wrongful activity (February 2018), and a January 2025 notice regarding rapidly proliferating sentiment-based virtual currencies (memecoins). Cybersecurity obligations on virtual currency licensees are layered with 23 NYCRR Part 500 (Cybersecurity Requirements for Financial Services Companies) and 23 NYCRR Part 504 (Transaction Monitoring and Filtering Program Requirements and Certifications). DFS operationalises supervisory excellence through the VOLT program: Vision, Operations, Leadership, and Technology. Licensed entities include Anchorage Digital NY, Bakkt Crypto Solutions, Bastion Platforms Trust Company, and many others; voluntary surrenders by Cboe Clear Digital, SoFi Digital Assets, Genesis, and Coinsource are publicly tracked. Inquiries: [email protected].
Pillar: Crypto & Sovereign Finance · Authority: New York State Department of Financial Services (NYDFS) - established under New York Financial Services Law; administers 23 NYCRR Part 200 (BitLicense) and limited purpose trust company chartering under New York Banking Law; license management through NMLS operated by Conference of State Bank Supervisors · Version: 1.0.0 · Last updated:
Primary source: https://www.dfs.ny.gov/virtual_currency_businesses
SHA-256 integrity: b12e709eff66a393ec1ec2166f6c99bec99c798462b336bb59cd40f4a9346cfb
Primary Citations — 18 traced to source
- 23 NYCRR Part 200 - Virtual Currency Regulation, issued June 2015 by the New York State Department of Financial Services under the New York Financial Services Law
- New York State Department of Financial Services - Virtual Currency Business Licensing page (https://www.dfs.ny.gov/virtual_currency_businesses)
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