On April 28, 2022, the New York State Department of Financial Services (“NYDFS”) issued its Guidance on Use of Blockchain Analytics (the “Blockchain Guidance”) to virtual currency business entities licensed or chartered in New York (“VC Entities”).  The guidance largely focuses on compliance with state and federal anti-money laundering (“AML”) requirements and with sanctions imposed by the U.S. Department of…

On April 28, 2022, a bipartisan group of legislators in the House of Representatives re-introduced and updated a bill regarding proposed regulatory oversight by the CFTC of crypto exchanges on which digital commodities are traded (the “Bill”).  The Bill was introduced by Republican Representatives Glenn Thompson of Pennsylvania and Tom Emmer of Minnesota and by Democratic Representatives Darren Soto of…

The Consumer Financial Protection Bureau announced on Monday it is planning to use a dormant statutory authority, section 1024(a)(1)(C) of the Consumer Financial Protection Act (CFPA), to conduct examinations of nonbank covered persons where the Bureau “has reasonable cause to determine, by order, after notice to the covered person to respond, … that such covered person is engaging, or has…

On April 4, 2022, Securities and Exchange Commission (“SEC”) Chair Gary Gensler spoke on the crypto markets at his alma mater, the University of Pennsylvania, for the Penn Law Capital Markets Association Annual Conference. While the speech did not break much new ground, it served as a reminder of the SEC’s priorities in the crypto space. During his speech, Gensler…

On March 16, 2022, the Consumer Financial Protection Bureau (“CFPB”) announced that it would combat perceived discrimination in the consumer financial marketplace by expanding its authority to target unfair, deceptive or abusive acts or practices (“UDAAPs”). Specifically, the CFPB directed examiners to scrutinize whether potentially discriminatory conduct may be unfair. The CFPB simultaneously published an updated exam manual for UDAAPs…