The New York State Department of Financial Services (NYDFS) recently issued guidance on the use of blockchain analytics for all virtual currency businesses that either have a BitLicense or are chartered as limited purpose trust companies under the New York Banking Law (VC Entities), emphasizing “the importance of blockchain analytics to effective policies, processes, and procedures, including, for example, those relating to customer due diligence, transaction monitoring, and sanctions screening.” The NYDFS continues to be concerned with the unique compliance challenges virtual currencies pose, while understanding they present new possibilities, including offering greater visibility into transaction lineage.
