On Jan. 14, New York state Sen. Zellnor Myrie proposed legislation in the New York State Senate that would amend New York law to make it a criminal offense to operate a virtual currency business in the state without the proper license.

By introducing the possibility of criminal penalties, S.B. 8901 — the Cryptocurrency Regulation Yields Protections, Trust and Oversight, or CRYPTO, Act — would mark a significant regulatory shift in how New York regulates virtual currency businesses.

For virtual currency businesses operating in New York and their counsel, the CRYPTO Act presents significant implications.

Crowell’s Carlton Greene, Anand Sithian, and Allison Fleming recently published an article in Law360 covering these developments, and proactive steps that market participants may wish to consider taking.

Click here to read the full article.

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

Photo of Allison Fleming Allison Fleming

Allison represents clients in internal and government investigations, regulatory enforcement actions, and white collar criminal defense matters. Allison is a member of the White Collar and Regulatory Enforcement practice group.

As part of her white collar practice, Allison counseled individuals who have appeared

Allison represents clients in internal and government investigations, regulatory enforcement actions, and white collar criminal defense matters. Allison is a member of the White Collar and Regulatory Enforcement practice group.

As part of her white collar practice, Allison counseled individuals who have appeared as witnesses in lawsuits and depositions, and she has assisted with investigations into corporate practices.

In law school, Allison was an executive editor on the Michigan Journal of International Law and a student attorney in the Human Trafficking Clinic. Allison also interned in the Civil Division of the U.S. Attorney’s Office for the Southern District of New York.