Ketsal and Hailey Lennon Comments on NYDFS’s Proposed Conditional BitLicense Framework

On the fifth anniversary of the BitLicense’s introduction, the New York State Department of Financial Services (“DFS”) announced that it was proposing to introduce a conditional BitLicensing framework pursuant to the DFS Superintendent’s authority under 23 NYCRR 200.4(c) and that it was seeking comments regarding the proposed framework. Under the conditional BitLicense framework, new entrants may work in collaboration with an existing BitLicensee or a holder of a NY limited purpose trust charter to conduct virtual currency business activity in New York, before eventually applying for a full BitLicense.