Overview

• Superintendent Adrienne Harris issued a Sept. 17 industry letter advising state‑chartered banks and New York‑licensed foreign branches to expand use of blockchain analytics when handling virtual currency activity.
• Recommended applications include screening customer wallets, verifying the origin of crypto‑linked funds, monitoring broader ecosystem exposure, and evaluating counterparties such as virtual asset service providers.
• Banks are encouraged to compare expected versus actual customer activity in virtual‑asset transactions, build risk assessments from network‑wide intelligence, and assess risks before offering new crypto products or services.
• NYDFS stressed that controls should be tailored to each institution’s risk profile with regular updates as markets, customers, and technologies evolve.
• The notice does not change state or federal law but extends prior 2022 guidance for licensed crypto firms into supervisory expectations for traditional banks handling digital‑asset exposure.