Partners Tiffany Smith, Zachary Goldman and Michael Held, Counsel Isabel Dai and Associate Benjamin Lobley authored an expert analysis published in Law360 in which they deep-dive into the key points of the New York State Dept. of Financial Services recently issued proposed guidance for virtual currency entities (VCEs). The proposed guidance updates the department’s self-certification framework for coins, introduces new policy requirements for coin listings and delistings, among other updates.
Excerpt: “The proposed guidance imposes new independence requirements for entities' board of directors or equivalent governing authority and requires VCEs to publicly disclose any conflicts of interest between a VCE or its affiliates and their owners, principals, employees or their respective families. It also requires VCEs to keep records of any documentation reviewed and produced by those responsible for approval and/or disapproval recommendations related to coin-listing and the risk assessment conducted on the specific coins under consideration.”
