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New York Publishes New Guidance and Proposed Changes to BitLicense on Five-Year Anniversary

On June 24, the five-year anniversary of New York’s virtual currency licensing regime known as the BitLicense, the New York Department Financial Services (DFS) published new guidance and FAQs related to approval for use of specific currencies and the licensing process, as well as a proposed conditional licensing framework. The measures offer important insight for… Continue Reading



On June 24, the five-year anniversary of New York’s virtual currency licensing regime known as the BitLicense, the New York Department Financial Services (DFS) published new guidance and FAQs related to approval for use of specific currencies and the licensing process, as well as a proposed conditional licensing framework. The measures offer important insight for companies holding or considering applying for a BitLicense and represent the most significant changes and proposed changes since the regulation’s initial issuance in 2015.

Guidance for Adoption or Listing of Virtual Currencies

Under the BitLicense regime, licensees and approved charter holders under the New York Banking Law (collectively, “VC Entities”) are required include virtual currencies (“coins”) they plan to “list” in their initial application to DFS. Historically, in order to list new assets VC Entities were required to go back to DFS to seek approval. Given the proliferation in coins available over the past five years this became a cumbersome and time-consuming system. In order to remedy this issue, in December of 2019, DFS issued proposed guidance to allow licensees to “offer and use new coins in a timely and prudent manner.” After receiving public comments, DFS has now published final guidance creating “two separate frameworks designed to enhance speed and efficiency in a VC Entity’s adoption or listing of coins.” These two frameworks include (1) “a general framework for a VC Entity’s creation of a firm-specific policy for the adoption or listing of a new coin, without DFS’s prior approval, through the process of self-certification” and (2) “a general framework for the process of Greenlisting coins for wider usage.”

Coin-Listing Policy

VC Entities wishing to self-certify the use of coins must create a coin-list policy in accordance with the DFS framework and such policy must be approved by DFS. According to DFS, the coin-listing policy must “include robust procedures that comprehensively address all steps involved in the review and approval of coins” and should only result in approval if the VC Entity concludes listing is consistent with standards contained in the BitLicense regime.

Notably, the guidance states that “a VC Entity cannot self-certify any coin that may facilitate the obfuscation or concealment of the identity of a customer or counterparty” meaning “no privacy coin can be self-certified.” Similarly, VC Entities “cannot self-certify any coin that is designed or substantially used to circumvent laws and regulations (for example, gambling coins).” Notably, the guidance does not define the term “privacy coin” or “gambling coin,” nor are such terms defined in the BitLicense regulations. Such coins are not completely banned under the guidance, but would require specific DFS approval as opposed to approval through self-certification.

Coin-listing policies must adhere to certain minimum standards related (1) governance, (2) risk assessment, and (3) monitoring. With respect to governance, the guidance requires the board of directors or equivalent body approve the coin-listing policy and each new listed coin. It also includes provisions related to conflicts of interest, record keeping, periodic reviews of the listing policy, and notifying DFS of instances of non-compliance. In addition, no changes or revisions to the policy can be made without prior written approval from DFS.

With respect to a risk assessment, the guidance states a VC Entity must “perform a comprehensive risk assessment designed to ensure that the coin and the uses for which it is being considered are consistent with the consumer protection and other standards embodied in [the BitLicense regime] and with the safety and soundness of the VC Entity.” The guidance then goes on to list 11 different risks that must be assessed for each new coin. For example, among other risks, VC Entities must assess “cybersecurity risk,” “risks associated with actual or potential conflicts of interest,” and “regulatory risks including those relating to federal regulations from the Financial Crimes Enforcement Network (FinCEN), the US Commodity Futures Trading Commission (CFTC), and the US Securities and Exchange Commission (SEC).” While not explicitly stated, the reference to CFTC and SEC suggest that VC Entities must be particularly cautious when considering listing of coins that might be considered a security under SEC rules or a derivative product under CFTC rules.

With respect to monitoring, the guidance states that “once a VC Entity begins using a new coin, the VC Entity should have policies and procedures in place to monitor the coin to ensure the VC Entity’s continued use of the coin remains prudent.” Such monitoring includes (1) periodic re-evaluation, (2) “adoption, documentation, and implementation” of internal controls to manage risks associated with listed coins, and (3) a process for de-listing coins.

Notably, for VC Entities with an approved coin-listing policy, while prior DFS approval is not required, such entities must “provide written notice to DFS of its intent to use the coin, including details of its specific use and purpose” prior to using the coin.

VC Entities without an approved coin-listing policy, must continue to seek pre-approval from DFS, unless the coin is contained in the DFS “Greenlist” (discussed below).

DFS Greenlist

DFS has published a Greenlist of approved coins that VC Entities may list without obtaining specific approval from DFS or going through the self-certification process. Coins can be added to the Greenlist through two mechanisms. First, coins can be directly approved by DFS. Second, coins that are approved by three “different and unrelated entities” through the self-certification process will be added to a public list of coins in a “Greenlist Waiting Period.” After six months the coin will be added to the Greenlist unless a VC Entity delists or stops using a given coin, in which case “DFS may decide whether or not to continue with the Greenlist Waiting Period based on any information it considers relevant.” Notably, coins are Greenlisted for “a specific use” as opposed to general purpose use. It is unclear from the guidance how broadly such uses will be construed. At present, the Greenlist includes two uses: “custody” and “listing.” However, these terms are not defined by DFS or in the BitLicense regulations and it is not clear if these are the only uses that DFS will consider adding to the Greenlist.

During the Greenlist Waiting Period, VC Entities can still seek to use the coin through either direct DFS approval or through the self-certification process. A VC Entity must have “policies and procedures in place to monitor its adoption and use of any coin on the Greenlist to ensure the VC Entity’s continued use of the coin remains prudent.”

The current Greenlist contained on DFS’s website is included below. Thus far, seven coins have been approved for “custody” and “listing” and an additional two coins have been approved for custody, but not for listing.

Transparency Requirements

The guidance states that VC Entities must provide their customers with written disclosures regarding offered coins, including whether a coin was approved by the Greenlist, self-certification, or specific DFS approval.

Notice Regarding Application Procedures

Industry has long complained the BitLicense application process is complex, lengthy, and, in some cases, lacks transparency. In a new notice published on the DFS website, it acknowledges these industry critiques and states that “in DFS’s experience, an underlying cause for these concerns is that BitLicense applications are often submitted without all the necessary documents and information.” In order to increase “transparency and speed in the BitLicense application review process,” DFS announced two new “practices.”

First, DFS will only begin a “substantive review” when an application includes “all the documents required … and each such document appears to be adequate on its face in terms of organization and level of detail.” DFS further explains that, “Applications that are not yet in this state will be deemed unready for substantive review until the missing items have been provided, and will generally not be reviewed, except for an initial intake process to determine whether substantive review is appropriate.” According to DFS this new practice will improve the review process by (1) expediting the review of applications considered ready for substantive review, (2) resulting in more applications being ready for substantive review by limiting “any incentive for applicants to submit partial applications,” and (3) resulting in “more effective and efficient use of DFS’s resources.”

Second, DFS will limit the number “deficiency letters” issued for a given set of requirements. A deficiency letter is a letter outlining a deficiency in a given portion of an applicant’s materials that must be remedied for a license to be issued. According to DFS, “these letters will include a return date by which a complete response is due” and “if all deficiencies involving a particular application requirement or set of requirements have not been fully and effectively addressed by the end of the response period for the third deficiency letter addressing the requirement(s), DFS may, without further notice, deny the application.” DFS explains that this policy will benefit applicants that diligently advance their applications once in the substantive review period and allow for more effective use of DFS resources.

The new practices announced by DFS underscore the importance of having a fully completed and well-crafted application package and responding promptly and fully to DFS deficiency letters, as well as working with experienced counsel that can assist in crafting policies and procedures likely to be approved by DFS. Whether the new practices will in fact speed processing times for applicants remains to be seen.

Updated FAQs

In addition to the guidance, discussed above, DFS also released a revised set of FAQs. The revised FAQs contain summaries of the new coin-listing frameworks and license application procedures. The FAQs also include a number of helpful responses regarding the scope of the BitLicense, for example, clarifying that “many” stablecoins are considered Virtual Currency under the BitLicense regime and that “writing software that allows customers to self-custody Virtual Currency in a wallet would not, in and of itself, require a BitLicense.”

Proposed Conditional Licensing Framework

Under the current BitLicense regulations, DFS may, at its discretion, grant a “conditional license” to an applicant that “does not satisfy all of the regulatory requirements upon licensing.” Conditional licenses may be granted for two years during which an entity must satisfy conditions imposed by DFS. At the end of the conditional license period DFS can allow the license to expire, remove the conditional status of the license, or extend the conditional license period. The conditional license mechanism was intended to provide an onramp to start-ups with more limited resources that may not meet all of the DFS requirements at the time of their application, but have a clear roadmap to come into full compliance in the future. However, to date, this conditional license has been of little interest to most members of industry given the inherent uncertainties of the process and significant resources required to obtain even a conditional license.

The proposed conditional licensing framework published by DFS recognizes the challenges facing some firms including the “rigorous application process, which can involve a significant expenditure of time and resources for applicants.” In order to ameliorate these challenges, DFS proposed a conditional licensing framework “to allow a new entrant to work in collaboration with an authorized BitLicensee or a holder of a New York limited purpose trust charter … during the term of the conditional BitLicense.” As explained by DFS, an applicant “seeking to engage in virtual currency business activity in New York under a Conditional License would collaborate and engage with an authorized VC Entity for various services and support, such as those relating to structure, capital, systems, personnel, or any other support needed.” DFS adds that it expects entities granted conditional licensing will eventually seek a full BitLicense. The proposed framework contains five steps:

  • An applicant will provide DFS a draft “service level or similar agreement” between the applicant and a VC Entity;
  • An applicant will submit certain additional documents and information based on the type of business the applicant plans to conduct and the risks presented by that business;
  • DFS will conduct a substantive review of the application materials;
  • If approved, DFS and the applicant will enter into a “supervisory agreement” that details, among other considerations, “the activities in which the Applicant may engage, the requirements it must meet, division, apportionment and sharing of responsibilities and liabilities with the VC Entity, and the oversight DFS will conduct with respect to the Applicant;” and
  • Upon completion of the supervisory agreement, DFS will issue the applicant a conditional license.

DFS is seeking comments from all interested parties regarding the proposed framework and lists 11 specific questions for which it is “particularly interested in receiving comments.” Both VC Entities and entities considering conducting business with VC Entities should review the proposed framework and consider submitting a comment with guidance from experienced counsel.

Notably, the proposed framework seems principally aimed at resolving the issue of entities seeking to provide certain services to VC Entities. For example, an entity wishing to provide custody solutions for a New York based VC Entity could be a potential candidate under the proposed framework. The framework seemingly has less utility for entities not looking to collaborate with existing VC firms, but rather to compete with those firms. For example, an entity looking to establish a new virtual currency exchange in New York to compete with other providers in the state would be unable to do so under the framework unless it found a willing VC Entity partner.

Steptoe will continue to monitor and provide updates on this proposed framework as DFS’s process unfolds.



GIBX Swap: Sky is the Limit for the Best Decentralized Exchange Platform

The era of decentralized exchanges has come with the maturity and application of digital technologies.



The value of GIBX Swap, which focuses on mainstream cryptocurrencies, is predicted to continue growing, shortly after its recent launch, and its price has the potential to reach record heights.

The first and leading decentralized exchange platform in the world has been launched on Sep.14,2021. Two days later, it is announced that GIBX Swap has started trading.

Meanwhile, due to its reputation, it has officially been listed on CoinMarketCap, the world’s most-referenced price-tracking website for cryptoassets in the rapidly growing cryptocurrency space. 

Decentralized tech and business

DeFi, shortened for Decentralized Finance, has been catching on since 2020. GIBX Swap holds the view that being decentralized is prerequisite to DEX. Traditional exchanges tend to be centralized.

On the one hand, it serves as information intermediaries, solving the issue of asymmetry of information to some extent; on the other hand, it create a new information asymmetry in favor of itself by the monopoly and manipulation of information, sometimes at the cost of the legitimate interests of clients.

No matter how the stock market performs, centralized exchanges can rely on charges and fees to guarantee their revenues.

As far as GIBX SWAP is concerned, the era of decentralized exchanges has come with the maturity and application of digital technologies. As a new type of exchange, the decentralized exchange makes the fullest use of the decentralization of blockchain, building peer-to-peer trust and transactions, with no intermediary.

The transaction links are all on the chain and performed directly by the open-source smart contract. As long as the user has and keeps the private key, he/she doesn’t have to worry about property security.

GIBX Swap features decentralized technologies with its brand-new block chain trading underlying platform, new generation of trading contract and cross-chain decentralized exchange, and complete business model with asset safety, market liquidity, trading fairness, ecological openness and transaction experience.

It aims to become the benchmark for DEX platforms and the leading DEX platform for token swaps.

GIBX Swap is an automated market maker (AMM) that allows a user to exchange two tokens. The liquidity provided to the exchange comes from Liquidity Providers (“LPs”) who stake their tokens in Liquidity Pools. In exchange, a user gets LP tokens that can also be staked to earn X tokens in the “Pool”.

Blockchain security protection from inside and outside

GIBX Swap puts emphasis on blockchain security protection. For one thing, it strengthens its own security from inside; for another thing, it has its smart contract technology code audited. Certik, the world’s leading block chain security audit institution has provided an audit for the project.

Established by the research team from Yale University and Columbia University with a decade of research, Certik has been providing code security audit services for blockchain applications and smart contracts, and the highest level of code security solution.

It is announced that GIBX Swap has passed the Certik security audit, which is carried out in a comprehensive review from Static Analysis, On-chain Monitoring, Social Sentiment, Governance & Autonomy, Market Volatility and Safety Assessment in search of potential safety hazards and possible production vulnerabilities.

It is confirmed once again after the audit by Certik that the technical code delivered by GIBX Swap is at a very high level of security, and GIBX Swap has the initiative to perform security tests.

Price predicted to reach new high 

GIBX Swap is highly committed to the supplier of true value, fairness, and innovation to decentralized finance through high-quality products and services.

It aims to become a benchmark for DEX platforms and take up the mantle of becoming the leading DEX platform on the market for token swaps. GIBX Swap is fast, secure no which anyone can swap and earn tokens.

A growing number of people has been paid attention to GIBX Swap ever since its launch. There have been over 46,000 followers in twitter, and more than 90,000 members in its TG.

GIBX Swap has shown strong potential lately and this could be a good chance to invest. Its value is expected to continue to expand, as shortage tends to encourage price rise.

In terms of price, GIBX Swap has an outstanding potential to reach new heights. X is forecast to increase in value. GIBX Swap can hit the highest price of $23.62 till 2030.

GIBX Swap is affiliated to GIBX, an international comprehensive Internet brokerage firm created by GIB Global Investment Bank & Capital Trust and a digital asset trading platform covering forex functions. GIBX has teamed up with world-renowned cryptocurrency platforms and top liquidity providers, including but not limited to: CoinMarketCap, CoinGecko, JPMorgan Chase, Goldman Sachs etc. in order to provide users a more transparent and convenient trading experience. As a financial trading platform regulated by international authorities such as FCA, ASIC, NFA, GIBX strictly follows all rules and regulations and uses reliable risk management solutions to ensure the safety of users’ capital.

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Solana, Polkadot, Algorand: What is the Bitcoin effect on these altcoins



With the market trading in red today pretty much all coins including Bitcoin and Ethereum are falling. However, there are some coins that made excellent gains in the last 2 months which are now facing huge price falls as well.

Which alts though?

Solana, Polkadot, and Algorand were three altcoins that successfully rallied between July and August. Polkadot rose from $12.34 all the way to $34.45 registering a 214.33% growth. Similar gains were observed for Algorand as the coin breached $2 and marked a 230.26% rise. 

The most gains were seen by Solana holders though mainly because the altcoin shot up 713.94%. An increase this high was the result of the NFT hype which took it up from $26.68 to $191.07

Solana’s 713% rise | Source: TradingView – AMBCrypto

In fact, Solana and Algorand even registered new all-time highs during this time period. But each of these coins is now observing significant price falls as well. 

In the last 24 hours ALGO fell by 15.26%, DOT came down by 14.37% and SOL lost 16.8% of its price as of press time.

A huge reason behind this fall is also their exhausted momentum since even after the September 7 fall, DOT and ALGO witnessed another price rise before they finally hit a slowdown.

Algorand’s 15.26% drop | Source: TradingView – AMBCrypto

Owing to this investors are possibly getting rid of their holdings in both spot and derivatives markets. Sell volumes at the time of this report have increased and liquidations rose to millions for all 3 altcoins. Since SOL gained the most, it lost the most as well and its liquidations touched $25 million.

Solana liquidations at $25 million | Source: Coinalyze – AMBCrypto

Can Bitcoin save them?

Well since Bitcoin’s price movement commands the market’s movement it is obvious that BTC needs to reduce losses first. But more importantly, these assets’ correlation to Bitcoin will determine how much they will be affected by BTC. Right now Algorand is at the lowest at 0.57, followed by Solana at 0.7, and at the highest is Polkadot (0.88)

However, surprisingly, investors are most positive about Algorand of all three hoping for a recovery soon.

Investor sentiment | Source: Santiment – AMBCrypto

Once Bitcoin and Ethereum change their movement, other coins would follow suit. And that’s when some recovery can be expected.

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Kraken Daily Market Report for September 19 2021




  • Total spot trading volume at $598.4 million, the 30-day average is $1.36 billion.
  • Total futures notional at $223.4 million.
  • The most traded coins were, respectively, Bitcoin (-2.2%), Ethereum (-3.1%), Tether (0%), Solana (-9.9%), and Cosmos (+8.8%).
  • Cosmos continues its hot streak, up 8.8%. Also strong returns from OMG (+10%).

September 19, 2021 
 $598.4M traded across all markets today

#####################. Trading Volume by Asset. ##########################################

Trading Volume by Asset

The figures below break down the trading volume of the largest, mid-size, and smallest assets. Cryptos are in purple, fiats are in blue. For each asset, the chart contains the daily trading volume in USD, and the percentage of the total trading volume. The percentages for fiats and cryptos are treated separately, so that they both add up to 100%.

Figure 1: Largest trading assets: trading volume (measured in USD) and its percentage of the total trading volume (September 20 2021)

Figure 2: Mid-size trading assets: (measured in USD) (September 20 2021)

###########. Daily Returns. #################################################

Daily Returns %

Figure 3: Returns over USD and XBT. Relative volume and return size is indicated by the size of the font. (September 20 2021)

###########. Disclaimer #################################################

The values generated in this report are from public market data distributed from Kraken WebSockets api. The total volumes and returns are calculated over the reporting day using UTC time.

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