Joseph A. Castelluccio

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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…

On October 4, 2022, the US Financial Stability Oversight Council (FSOC) released its Report on Digital Asset Financial Stability Risks and Regulation (FSOC Report).  Weighing in at over 120 pages, the FSOC Report provides a thorough discussion of the regulation of crypto-assets and their potential financial stability risks. Most importantly, the report sets forth several…

On September 16, 2022, the Treasury Department issued three reports pursuant to President Joseph Biden’s March 9 Executive Order 14067 on “Ensuring Responsible Development of Digital Assets.” The issuance of the reports was followed by Treasury Under Secretary for Domestic Finance Nellie Liang giving remarks at the Brookings Institution on September 22 explaining the reports…

On March 9, 2022, President Biden signed an executive order titled “Ensuring Responsible Development of Digital Assets” (the “Order”). The Order directs a broad range of federal agencies to recommend legislative and regulatory proposals to foster the development of, and address the risks presented by, digital assets and a central bank digital currency. This Legal…

On November 1, 2021, the President’s Working Group on Financial Markets (PWG) released its much-anticipated Report on Stablecoins. The Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency joined the PWG in issuing the report, which provides an overview of how stablecoins are created and operate, discusses the risks they present…