The New York State Department of Financial Services and the Wyoming Division of Banking announced on 1 October 2026 that they have signed a memorandum of understanding establishing coordinated oversight of entities engaged in virtual currency and digital asset activities. DFS Acting Superintendent Kaitlin Asrow and Wyoming Division of Banking Commissioner Jeremiah Bishop signed for their agencies. The memorandum is an executed supervisory arrangement between two state regulators, not a rulemaking, and it alters no licensing obligation on its own.
Licensing obligations in New York continue to rest on 23 NYCRR Part 200, the virtual currency regulation that took effect on 24 June 2015. Under 23 NYCRR 200.3(a) no person may engage in Virtual Currency Business Activity without a licence obtained from the Superintendent. 23 NYCRR 200.2(q) defines that activity to cover receiving or transmitting virtual currency, storing, holding or maintaining custody or control of virtual currency on behalf of others, buying and selling virtual currency as a customer business, performing exchange services as a customer business, and controlling, administering or issuing a virtual currency. A business chartered under the limited purpose trust company provisions of the New York Banking Law may conduct virtual currency business with the approval of the Superintendent in place of a BitLicense.
Firms holding a BitLicense or a New York limited purpose trust company charter that also operate in Wyoming, and Wyoming chartered institutions entering New York, face one coordinated review rather than two unconnected ones. The two regulators will share analysis, subject matter reviews and historical examination data where an entity is licensed in one state or applies in both at the same time. On supervision they will coordinate examination schedules, work towards joint examinations of entities operating in both states, and exchange supervisory reports, market trend data and notices about potential enforcement actions.
The memorandum does not create a passport. A firm still needs its own authorisation in each state, and the published announcement sets no processing deadline or service standard for coordinated applications. Information sharing that extends to notices about potential enforcement actions means a supervisory concern raised in one state can reach the other before any public step is taken.
Licentium advises digital asset businesses on United States state money transmission, virtual currency licensing and multi-state supervisory exposure. Work we undertake includes mapping which activities fall inside 23 NYCRR 200.2(q), preparing BitLicense and limited purpose trust company applications, and assessing how coordinated state examinations affect group compliance reporting.
Source: New York State Department of Financial Services, press release, 1 October 2026