In June of 2015, DFS issued virtual currency regulation 23 NYCRR Part 200 under the New York Financial Services Law. Since then under that “BitLicense” regulation or the limited purpose trust company provisions of the New York Banking Law, DFS has granted numerous virtual currency licenses and charters to ensure that New Yorkers have a well-regulated way to access the virtual currency marketplace and that New York remains at the center of technological innovation and forward-looking regulation.
Questions regarding virtual currency business activity in New York State may be referred to DFS at [email protected] and should include your full contact information.
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To address delays in regulatory processes and ensure operational excellence across the Virtual Currency unit, DFS has implemented and supported a series of measures under Superintendent Harris’s supervision, known as VOLT:
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To conduct virtual currency business activity in New York State, entities can either apply for a BitLicense or for a charter under the New York Banking Law (for example, as a New York State limited purpose trust company or New York State bank) with approval to conduct virtual currency business. While these forms of authorization are similar, a New York State limited purpose trust company charter may provide some additional benefits. For example, a limited purpose trust company can exercise fiduciary powers, while a BitLicensee cannot. In addition, a limited purpose trust company can engage in money transmission in New York without obtaining a separate New York money transmitter license. For more information about applying for a limited purpose trust charter, visit Commercial Banks & Trusts.
The Department of Financial Services uses the Nationwide Multistate Licensing System and Registry (NMLS) to manage the BitLicense. NMLS is a secure web-based system created by state regulators to provide efficiencies in the processing of state licenses and improve supervision of state-regulated industries. Through NMLS, companies maintain a single record to apply for, amend, surrender and change license authorities in one or more states, and make reports conveniently and safely online.
To enter information into NMLS, you must first complete a Company Account Request Form and identify a Primary Account Administrator and a Secondary Account Administrator. This form can be submitted electronically through the NMLS website in the “Getting Started” section. This form needs to be submitted only once per company, regardless of the number of NMLS participating states in which you are licensed.
Within three days of completing and submitting the Company Account Request Form, the Primary Account Administrator will receive NMLS login information. The Primary Account Administrator will have full rights to access the system, submit information to this agency and other participating state regulators, and set up other company users in the system. Instructions and tutorials on how to access and use the system are also available in the NMLS Resource Center.
Each company holding a BitLicense that wishes to manage its license on NMLS must create a company record in the system (see above). Current New York State BitLicensees whose applications were submitted before the integration of the BitLicense into NMLS may transition their licenses to NMLS. See the NY Virtual Currency Business Activity Company License Transition Checklist on the NMLS website for more information.
To submit an application, please follow the instructions on the NY Virtual Currency Business Activity License New Application Checklist (the “BitLicense Application Checklist”). You can view the BitLicense Application Checklist any time, even before you have an NMLS account. The BitLicense Application Checklist is a critically important guide for anyone considering applying for a BitLicense. Before submitting a BitLicense application, please read the BitLicense Application Checklist carefully. BitLicense applications must generally contain all items described in the BitLicense Application Checklist. Failure to submit all of these items, as described, is the most common reason for delays in the application process.
Please note: An application will not be deemed ready for substantive review until the Department has received all required information, documents, and fees, as described in detail in the BitLicense Application Checklist, and the required documents appear to be facially adequate in terms of organization and level of detail. (Exceptions may be made if deemed appropriate by DFS in light of specific circumstances.) Applications that are not ready for substantive review generally will not receive detailed expert review by DFS staff. Thus, the processing of an application that does not contain all items as described in the BitLicense Application Checklist may be delayed indefinitely, and ultimately the application may be denied for insufficiency. For more information on the Department’s application review process, please see DFS’s Notice of Virtual Currency Business Activity License Application Procedures.
Please also note that, in the process of considering an application, DFS may request additional information and supporting documents, beyond those found in the BitLicense Application Checklist.
Prospective applicants who have questions about the application process can send their questions to the DFS Virtual Currency Unit staff, at [email protected]. If it appears that an applicant would benefit from a more interactive dialogue, DFS staff may recommend a pre-application call or meeting (virtual or in person), at the appropriate time.
In the application process, an NMLS Identification Number will be assigned to your application. Please maintain a record of this NMLS Identification Number, as it will be used as your application reference number throughout the remainder of the process. The applicant’s NMLS Identification Number must be included on every hard-copy document submitted to the Department.
Note: If the applicant has already submitted Forms MU1 and MU2 through NMLS for another state, the applicant does not need to re-enter the company record into NMLS. However, the applicant is required to provide jurisdiction-specific information to support its New York State application.
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2022-09-14
Notice Regarding Ethereum’s Upcoming Protocol Change
2022-06-08
Guidance on the Issuance of U.S. Dollar-Backed Stablecoins
2022-04-28
Guidance on Use of Blockchain Analytics
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2020-06-24
Notice of Virtual Currency Business Activity License Application Procedures
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Guidance Regarding Adoption or Listing of Virtual Currencies
2020-06-24
Request for Comments on a Proposed Framework for a Conditional BitLicense
Proposed Guidance Regarding Adoption or Listing of Virtual Currencies
2018-02-07
Guidance on Prevention of Market Manipulation and Other Wrongful Activity (PDF)
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Updated: October 14, 2022
Apex Crypto LLC
Bakkt Marketplace, LLC
Virtual Currency and Money Transmitter Licenses
2021-03
Bakkt Trust Company LLC
Limited Purpose Trust Charter
2019-08
bitFlyer USA, Inc.
Virtual Currency License
2017-11-28
BitGo New York Trust Company LLC
Limited Purpose Trust Charter
2021-03
BitOoda Digital, LLC
Bitpay, Inc.
Virtual Currency License
2018-07
Bitstamp USA, Inc.
Virtual Currency License
2019-04
Block, Inc., f/k/a Square, Inc.
Circle Internet Financial, Inc.
Virtual Currency and Money Transmitter Licenses
2015-09
Coinbase Custody Trust
Limited Purpose Trust Charter
2018-10
Coinbase, Inc.
Virtual Currency and Money Transmitter Licenses
2017-01
Coinsource
Virtual Currency License
2018-11
Cottonwood Vending
Virtual Currency License
2019-01
Eris Clearing, LLC
Virtual Currency and Money Transmitter Licenses
2020-05
Fidelity Digital Asset Services, LLC
Limited Purpose Trust Charter
2019-11
Gemini Trust Company, LLC
Limited Purpose Trust Charter
2015-10
Genesis Global Trading, Inc.
Virtual Currency License
2018-05
GMO-Z.com Trust Company, Inc.
LibertyX/Moon Inc.
Virtual Currency License
2019-01
NYDIG Execution LLC
Virtual Currency and Money Transmitter Licenses
2018-11
NYDIG Trust Company LLC
Limited Purpose Trust Charter
2018-11
Paxos Trust Company, LLC (f/k/a itBit Trust Company, LLC)
Limited Purpose Trust Charter
2015-05
PayPal, Inc.
Virtual Currency and Money Transmitter Licenses
2022-06*
Provenance Technologies, Inc.
Ripple Markets DE LLC (f/k/a XRP II LLC)
Robinhood Crypto
Virtual Currency and Money Transmitter Licenses
2019-01
SoFi Digital Assets
Virtual Currency and Money Transmitter Licenses
2019-11
Standard Custody & Trust Company, LLC
Zero Hash Liquidity Services, LLC
*formerly known as Seed Digital Commodity Market, LLC
Zero Hash LLC
Virtual Currency and Money Transmitter Licenses
2019-07
*The Department granted PayPal, Inc. a conditional virtual currency license in October 2020 and a money transmitter license in October 2013.
**The Department granted Provenance Technologies, Inc. a money transmitter license in October 2021 and the virtual currency license in February 2022.
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There are multiple paths virtual currency businesses can take to adopt or list virtual currencies:
For more information, please see Guidance Regarding Adoption or Listing of Virtual Currencies and Coin-Listing Process infographic.
Regulated entities engaged in Virtual Currency Business Activity may submit to DFS a self-certification policy, pursuant to guidance DFS issued in June 2020. Once DFS approves such a policy and the entity seeks to self-certify a coin for listing or custody, it must submit a self-certification form. Certifications should be submitted via the secure DFS Portal. To access the DFS Portal you will need to create a portal account.
When you first log in, click on Ask for Apps to request access to the Virtual Self-Certification application, for the company(ies) you will be filing for. When this is approved, you will be able to access this application in the My Apps menu.
DFS Portal
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Any entity licensed by DFS to conduct virtual currency business activity in New York may use coins on the Greenlist for their approved purpose(s). Note that if a licensed entity decides to use a coin on the Greenlist, it must inform DFS prior to beginning its use.
Updated: June 3, 2022
0x
Aave
Bancor Network Token
Basic Attention Token
Binance USD*
BUSD
X
X
Bitcoin
BTC
X
X
Bitcoin Cash
BCH
X
X
Chainlink
LINK
X
X
Dogecoin
DOGE
X
Ethereum Classic
ETC
X
Ethereum
ETH
X
X
Gemini Dollar*
GUSD
X
X
GMO JPY
GYEN
X
X
Kyber Network
KNC
X
Litecoin
LTC
X
X
Livepeer
LPT
X
Lumens
XLM
X
OmiseGO
OMG
X
Pax Gold
PAXG
X
X
Pax Dollar*
USDP
X
X
Ripple
XRP
X
Synthetix
SNX
X
Wrapped Bitcoin
wBTC
X
Z.com USD*
ZUSD
X
X
* denotes USD-backed stablecoins issued by DFS-regulated entities that have been approved for issuance.
The Department tracks those coins for which it has given individual entities approval to custody and list, as well as those coins individual entities have self-certified to the Department. For a complete list of those coins, click here.
Disclaimer: DFS may, at any time and in its sole discretion, prohibit or otherwise limit a coin’s use before or after a VC Entity begins using a coin; require that any VC Entity delist, halt, or otherwise limit or curtail activity with respect to any coin; remove any coin from the Greenlist; refrain from placing any coin on the Greenlist; or discontinue the Greenlist process entirely.
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As an example, writing software that allows customers to self-custody Virtual Currency in a wallet would not, in and of itself, require a BitLicense. However, building a wallet service in which you kept custody of other people’s funds on their behalf likely would require a BitLicense.
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This chart is for illustrative purposes only. For more information Refer to the coin-listing guidance issued June 24, 2020. DFS retains the discretion to deny a coin’s use or addition to the Greenlist.
Print-friendly version (PDF)
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Updated: February 14, 2022
Digital Asset
Symbol
#
Listing
#
Custody
1Inch
1INCH
1
1
0x
ZRX
2
Greenlisted
Aave
AAVE
Greenlisted
Greenlisted
Algorand
ALGO
1
2
Amp
AMP
2
2
Ankr
ANKR
1
1
Aragon
ANT
1
0
Audius
AUDS
0
1
Balancer
BAL
2
2
Bancor Network Token
BNT
Greenlisted
Greenlisted
Band Protocol
BAND
1
1
Barnbridge
BOND
1
1
Basic Attention Token
BAT
Greenlisted
Greenlisted
BCAP
BCAP
0
1
Bitcarbon Bar
BCB
0
1
Bitcarbon Coin
BCC
0
1
Bitcoin Gold
BTG
0
1
Bitcoin SV
BSV
0
1
Bread
BRD
0
1
Cardano
ADA
1
1
Caspian
CSP
0
2
Celo
CELO
1
1
Celo Dollar
CUSD
1
1
Chainlink
LINK
Greenlisted
Greenlisted
Civic
CVC
1
1
Compound
COMP
1
2
Compound 0x
cZRX
0
2
Compound Basic Attention Token
cBAT
0
2
Compound Compound
cCOMP
0
1
Compound Dai
cDAI
0
2
Compound Ethereum
cETH
0
2
Compound USD Coin
cUSDC
0
1
Compound Wrapped Bitcoin
cWBTC
0
1
Cosmos
ATOM
1
1
CryptoPing
PING
0
1
Cube
AUTO
1
1
Curve
CRV
1
2
Dai
DAI
2
2
Decentraland
MANA
2
2
Division Network
DVI
0
1
Dogecoin
DOGE
2
Greenlisted
Elrond
EGLD
0
1
Enjin Coin
ENJ
1
1
Ethereum Classic
ETC
2
Greenlisted
EOS
EOS
0
2
Ferrum Network
FRM
0
1
Fetch.ai
FET
1
0
Filecoin
FIL
2
0
Flexacoin
FXC
0
1
FOAM
FOAM
1
1
FTX
FTX
0
1
Golem
GNT
1
2
The Graph
GRT
2
2
Handshake
HNS
1
1
Horizen
ZEN
0
1
Injective Protocol
INJ
1
2
Keep Network
KEEP
1
1
Kin
KIN
0
1
Kyber Network
KNC
2
Greenlisted
Livepeer
LPT
Greenlisted
2
Loom Network
LOOM
1
2
Loopring
LRC
1
1
Lumens
XLM
2
Greenlisted
Maker
MKR
2
2
Meta
MTC
1
0
NKN
NKN
1
1
Numeraire
NMR
0
2
Ocean Protocol
OCEAN
0
1
OmiseGO
OMG
1
Greenlisted
Ontology
ONT
1
1
Orbs
ORBS
1
1
Orchid
OXT
2
2
Origin Protocol
OGN
1
1
Polygon
MATIC
2
2
Polymath
POLY
1
1
Props
PROPS
0
1
Refereum
RFR
0
1
Ren
REN
2
2
Request
REQ
0
1
Reserve
RSR
1
1
Ripple
XLM
2
Greenlisted
The Sandbox
SAND
1
1
Serum
SRM
0
1
Siacoin
SC
1
1
Skale
SKL
2
2
Spice
SPICE
0
1
Stacks
STX
0
1
Storj
STORJ
1
2
SUKU
SUKU
1
1
SushiSwap
SUSHI
1
1
Synthetix
SNX
Greenlisted
2
tBTC
tBTC
1
2
Tezos
XTZ
0
1
Unibright
UBT
0
1
Uniswap
UNI
2
2
Universal Market Access
UMA
2
2
Unstoppable Domains
0
1
USD Coin
USDC
2
2
Utrust
UTK
0
1
Wrapped Bitcoin
wBTC
1
Greenlisted
Wrapped Nexus Mutual
wNXM
1
2
XYO
XYO
0
1
Yearn Finance
YFI
2
2
YFII Gold
YFII
1
1
Zilliqa
ZIL
0
1
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As stated in 23 NYCRR 200.3(a), “No Person shall, without a license obtained from the superintendent …, engage in any Virtual Currency Business Activity.”
23 NYCRR 200.2(q) provides, in part: “Virtual Currency Business Activity means the conduct of any one of the following types of activities involving New York or a New York Resident:
For licensing requirements see 23 NYCRR Part 200.
The virtual currency landscape has evolved substantially since the first bitcoin launched in 2009. In New York, DFS has been regulating virtual currency business activity since 2013. A brief timeline of events leading to and following the BitLicense regulation in June 2015 follows:
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