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$8 million penalty to NYDFS – and another case of over-retention

January 24, 2024

2024 was not a happy new year for Genesis Global Trading, Inc. (“GGT”).  On January 3, 2024, the New York Department of Financial Services announced a consent order with GGT, where GGT agreed to pay NYDFS $8 million and to surrender its BitLicense (for cryptocurrency trading), due to alleged violations of NYDFS’ cybersecurity and its virtual currency regulations.  This post will focus on the cybersecurity regulation issues.  (For more information about the crypto and financial services/regulation aspects, please see

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