On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related activity (“2022 Guidance”). The 2022 Guidance is similar to prior notice guidance issued by the federal banking regulators but establishes highly prescriptive information requirements
David Beam is a partner in Mayer Brown’s Washington DC office and a member of the Consumer Financial Services group. His practice encompasses a broad range of matters related to payments and credit regulation. He provides clients with regulatory compliance and related business planning advice; conducts regulatory due diligences of investment and acquisition targets; structures joint ventures and other business arrangements; obtains approvals, licenses and regulatory guidance from US federal and state financial regulators; and prepares terms and conditions for financial products and services. Additionally, he defends companies in connection with federal and state governmental audits, investigations and enforcement proceedings and assists with litigation matters, including putative class action proceedings.