by Sam Brylski
On February 4, 2015, the New York State Department of Financial Services (NYDFS) released revisions to their proposed BitLicense regulation of virtual currencies. Though it will not be finalized until the end of an additional 30-day comment period at the earliest, this proposal is unlikely to undergo any more significant changes.
This primer will attempt to break down the details of the BitLicense, beginning with its purpose and scope. Next, I will outline the major obligations a BitLicense imposes on the Licensee, such as anti-money laundering obligations, cyber security requirements, and the requirement to report any material change to business services. Finally, I will discuss the application cost and process…