Poloniex Pursuit: Former Crypto Exchange Volume Leader Hits Reset, Circle Spins Off

Back in late 2017 Poloniex was the place to be in crypto. The hands down volume leader and alt-coin king that managed nearly 60% of stated crypto exchange trading volume. Those halcyon days are long past and Poloniex now processes less than 1% of the industry’s trading volume. One could call Circle’s $400M acquisition a disaster, but that might just be a bit too kind.

Via Poloniex’s blog today:

” We are excited to announce that we are spinning out from Circle into a new company, Polo Digital Assets, Ltd., with the backing of a major investment group. The spinout will free us to focus on the needs of global crypto traders with new features, assets and services. Our first new offer to Poloniex traders is that effective October 21, 2019, all spot trading fees will be reduced to 0% until the end of the year. Poloniex intends to continue beyond that with highly competitive and creative pricing models for traders.”

The advent of KYC and AML destroyed Poloniex’s leadership position as most users ignored the new regulatory requests and took their account, eventually, to Binance. Binance, of course, is the current leader amongst crypto exchanges when it comes to volume.

Poloniex attempt to shift back to a stand alone entitiy as well as ‘re-brand’ is interesting and worth watching. But a ‘death spiral’ is just that when it comes to exchange volume. Volume is the game when it comes to any exchange anywhere, in crypto or in traditional finance. Cut and dried. Two years go Poloniex was the unquestioned volume leader; now, they are just a footnote.

Bitso Is The Belle Of The Ball: Who’s Who Of Crypto Invest In Mexico-based Exchange

Bitso is this weeks ‘it’ girl, grabbing investment dollars from Ripple, Coinbase, Jump Capital, DGC, and Pantera. A literal who’s who of investment partners that have decided there is plenty of value still to be extracted from the trading of digital assets abroad.

” As reported by crypto publication The Block, the new investment round also involves major investors including United States-based crypto exchange and wallet provider Coinbase, Jump Capital as well as existing investors such as Digital Currency Group and Pantera Capital. The amount of investment has not been disclosed.”

Even though the amount of the investment has yet to be disclosed, you can bet it isn’t a peasants wage. One of, if not the most, profitable areas of the crypto space is the exchange ecosystem. BitMex and Binance regularly book revenues in the tens of millions, if not hundreds, on a quarterly basis. The consortium of investors are betting that their capital and advice could serve to push Bitso into that same stratosphere.

According to the report, the raised funds will help Bitso expand its business to Argentina and Brazil, among other Latin American countries.

As noted by Ripple, Bitso is the largest Mexican crypto exchange that was established in 2014 with a purpose to provide financial services for both banked and unbanked with blockchain technology and digital assets. To date, the customer base of the exchange accounts for 750,000 users.

Noting that its partnership with Bitso takes roots from the company’s beginning in 2014, Ripple says that the firm plays an important role in RippleNet’s United States-Mexican corridor by providing liquidity for payments. Earlier in 2019, Ripple launched On-Demand Liquidity (ODL) capabilities with MoneyGram into Mexico, where Bitso was a key exchange partner, Ripple added.

Bitwise ETF Denied; Bitcoin ETF Strategy Adjusts, May Follow VanEck

In an expected move the SEC denied the ETF submission of Bitwise and penned a long and detailed ‘opinion paper’ that documented the decision. That decision was widely expected by experts across the crypto ecosystem, and yet developments have ensued. Most notably, Bitwise’s response to the decision.

The verdict on Bitwise’s ETF proposal had seen multiple delays prior to this week’s final decision, which the SEC had no choice but to make, according to statutory rules. The news release states:

“We deeply appreciate the SEC’s careful review. The detailed feedback they have provided in the Order provides critical context and a clear pathway for ETF applicants to continue moving forward on efforts to list a bitcoin ETF. […] We look forward to continuing to productively engage with the SEC to resolve their remaining concerns, and intend to re-file as soon as appropriate.”

Bitwise’s response denotes a path forward, but hedges with “…re-file as soon as appropriate.” That doesn’t say ‘as soon as possible’ – an important distinction.

“We’re closer than we’ve ever been before to getting a Bitcoin ETF approved,” CEO Matt Hougan told mainstream media on Oct. 7. 

Still, more than a year-long dialogue with regulators has not been for nothing, says the company, concluding:

“While we were not able to satisfy the SEC’s concerns inside the statutory 240-day review window afforded these filings, and while they have identified the need for additional data and context to interpret our key findings, we are pleased with the progress that the industry has made and believe that, with additional research and continued progress in the broader ecosystem, the remaining concerns and challenges raised in this order will ultimately be satisfied.”

In September, another ETF proposal, this time from VanEck and SolidX, was withdrawn by its sponsors. VanEck, notably decided on a wholly separate route that has seen the firm garner significant institutional interest in its Bitcoin product.

We wonder, will Bitwise choose a similar path, somewhat dodging regulators altogether, ergo; ultimately forcing their hand? Time will tell.

INSIDER: CFTC AND ETHEREUM: As The CFTC Requests Ethereum Comments, Insider Considers Commodity Designation A ‘Done Deal’

Previously the CFTC formally requested ‘public comment’ concerning whether or not Ethereum should be designated as a commodity or not (the ‘not’ would then throw it into the security designation and open up a whole mess of issues). Obviously, Ethereum and every coin/dapp that has been built on it has a vested interest in a commodity designation by the CFTC.

Here is the body of the request by the CFTC:

The Commodity Futures Trading Commission (“Commission” or “CFTC”) in furtherance of the LabCFTC initiative is seeking public comment and feedback on this Request for Input (“RFI”) in order to better inform the Commission’s understanding of the technology, mechanics, and markets for virtual currencies beyond Bitcoin, namely here Ether and its use on the Ethereum Network. The Commodity Exchange Act (“CEA”) grants the Commission regulatory authority over the commodity futures markets. The Commission is seeking public feedback in furtherance of oversight of these markets and regulatory policy development. The input from this request will advance the CFTC’s mission of ensuring the integrity of the derivatives markets as well as monitoring and reducing systemic risk by enhancing legal certainty in the markets. The RFI seeks to understand similarities and distinctions between certain virtual currencies, including here Ether and Bitcoin, as well as Ether-specific opportunities, challenges, and risks. The Commission welcomes all public comments on these and related issues.

Many have made the case that Ethereum is significantly more ‘centralized’ than Bitcoin and thus have serious questions about its commodity-type traits. Others believe that the breadth of the ERC-20 (at a minimum) ecosystem makes the case for its decentralization – thus making it a clear commodity.

Whatever the arguments are either way we believe, based on one conversation with a staffer at the CFTC, that the request for comment is a mere formality. Internally the decision to designate Ethereum as a commodity is all but made.

**We have two separate and reliable sources connected to the CFTC. One was willing to give us an anonymous comment, the other spoke with us but asked that the comments be left out of this article.

As per the thinking at the CFTC:

“The request for comment is seen as a reasonable procedural process to check the box before announcing the commodity designation. Chris understands the digital assets landscape really, really well and knows that there is less consensus on this than there was for Bitcoin. This step will give some background to the decision and he expects the comments to be largely in favor of a commodity designation.”

Any policy decision in the crypto space will have long-lasting and even unintended consequences. It makes sense to consider every angle and every reasonable outcome of a commodity designation for Ethereum. Several institutions are counting on the decision going in that direction.

ErisX, Bakkt, Fidelity, ETrade, TD Ameriprise, and others have plans to list/trade Ethereum based on its eventual designation as a commodity. ErisX has already announced its intentions, Bakkt initially listed Ethereum as one of its two launch tokens before they decided to wait for the formal word from the CFTC, and Goldman Sachs is preparing to offer an Ethereum based product for its upper-crust clients.

The ripple effects of this decision will resonate throughout 2019 and give context to every other token that claims to be a commodity/utility and not a security.

The CFTC and Chris Giancarlo are playing it smart.

MARK CUBAN: Bitcoin, Gold, and Bananas? Cuban Is All Over The Place On BTC

Mark Cuban is a renowned entrepreneur, Dallas Mavericks owner, TV personality, and highly sought after interview. But a crypto expert he is not. In a far ranging interview the topic of Bitcoin and crypto were raised and ‘The Cubes’ was all over the place; at times sounding like a no-coiner and others like a hodler.

“I say it’s like gold. Gold is a religion: people who are really into gold — they’ll tell you that there’s a bad depression and things go to hell in a handbasket, if you own gold then you’ll be okay. No, you won’t! You carry around a gold bar — someone’s gonna hit your ass, knock you out and steal your gold bar and it’s gonna happen again and again and again. I’d rather have bananas, I can eat bananas. Crypto… Not so much.”

Comparing Bitcoin to gold is a reasonable position and not necessarily out of the mainstream. But that isn’t where he stops.

“Did you ever see someone who collected baseball cards? And they were really, really, really proud of their baseball cards because they kept saying they were going to go up in price? Comic books — same thing, even artwork. There’s no real intrinsic value, you can’t eat a baseball card […] Your artwork might look good on the wall but not much you can do with it. Bitcoin — there’s even less you can do with it: at least I can look at my baseball card […] I can look at artwork.”

I don’t know, the high end art markets have performed pretty well over the past decade. Cuban goes on to echo one of Warren Buffet’s lamest Bitcoin takes, connecting the digital asset to being valued at ‘whatever someone will pay for it’. Which of course is the literal definition of value in a free market economy. Lulz.

“Here’s the thing about crypto, particularly Bitcoin: Bitcoin is worth what somebody will pay for it.”

But as the interview comes to a close, Cuban comes full circle and all but proves that he probably holds some Bitcoin in his portfolio.

“Look, all I am saying is to be careful what you invest in. At worst Bitcoin and other cryptocurrencies are ‘stored value’, I’m not sure what they are at their best.”

Bananas, baseball cards, artwork, gold, and yet, stored value. A crypto expert Mark Cuban is not.

JP MORGAN COIN: Privacy Is Paramount; Bank Aims To Hide Transaction Details

JP Morgan seems to be listening to some of the serious discussions within the crypto community. Specifically, the issue of privacy. And while most wouldn’t associate the largest bank in the world with the idea of privacy they seem to be taking notes as to what matters most to the movement: privacy.

**before we go further let’s make one thing clear – we do. Or believe that JPM will actually build a token that finds itself outside of the reach of US and global regulators. So ‘privacy’ in this context is limited.

As per a CoinDesk post moments ago: “Revealed exclusively to CoinDesk, JPMorgan has built an extension to the Zether protocol, a fully decentralized, cryptographic protocol for confidential payments, compatible with ethereum and other smart contract platforms and designed to add a further layer of anonymity to transactions. The New York-based financial institution will open-source the extension Tuesday, and is likely to use it with Quorum, the bank’s homegrown, private version of ethereum.”

“Zether, which was built by a group of academics and financial technology researchers including Dan Boneh from Stanford University, uses zero-knowledge proofs (ZKPs), a branch of mathematics which allows one party to prove knowledge of some secret value or information without conveying any detail about that secret.”

So privacy, in this case, means the ability to conceal the transaction addresses and the amounts that are being sent and received. This is about as far as a heavily regulated organization like JP Morgan could ever get away with, and even this is probably pushing the limits.

Still, from 50,000 feet, this is an effort that pushes the crypto narrative along in earnest. JPM using crypto industry products to open source their entry into the space adds a significant level of validation – even if some in crypto aren’t interested in this type of validation.

It will be interesting to eventually see what JPM unveils and how it is used in both the institutional and retail space.

MORGAN STANLEY COPYCAT: FOLLOW FIDELITY: Morgan Stanley Is Watching Fidelity’s Digital Assets Initiative Closely, Planning Similar Offering

Morgan Stanley has seemingly been planning some sort of crypto initiative for longer than their clients can wait. According to sources at the global investment bank, clients (institutional and UHNW retail) have grown impatient with Morgan Stanley and ‘talk’ of crypto accessibility.

The sources discussed a small percentage of the client base keeps asking the firms bankers and brokers why they aren’t out in front in regards to crypto. Specifically, a straight line is being made by some as to Goldman Sach’s (it is well known in traditional finance that Morgan Stanley and Goldman Sachs are bitter rivals) consistent investments in the crypto ecosystem, BitGo and Circle, to name just a couple.

Those Goldman Sachs led investments position the firm to quickly scale up once the regulatory landscape is clear and defined. Morgan Stanley hasn’t made those any ‘in-kind’ investments that match Goldman’s and clients and brokers have been grumbling about it.

But there may be some hopes according to two sources that we spoke to at the bank. Morgan Stanley leadership is enamored with the path that Fidelity is taking and believe they can take the same path – and fashion it to be of interest to the firms largest institutional and UHNW clients.

“Are we behind? Yes. That really can’t be disputed at this point.” said our first source near the top of the communications org chart at Morgan Stanley. “But that won’t be the case once we commit to a particular strategy. We believe we are well positioned when the time is right.”

A second source closer to the broker ranks had this to say, “The word we hear is that leadership finds the Fidelity model for crypto appealing. And that could be the way it goes down here. Whatever strategy they choose, it needs to come quickly. We are getting asked about it daily. It does seem like clients that are aware of Bitcoin in particular see it as digital gold. That phrase has popped up often with UHNW clients.”

The digital gold narrative from uber-wealthy individuals and families is interesting. It means, if nothing else, that for those looking for Bitcoin information, the digital gold narrative is resonating.

“Clients that ask about crypto seem to be aware of Bakkt as well and question us as to our involvement and accessibility within their framework”, our second source described. “It is revealing what messaging seems to be making its way into these clients hands and sticking. Bakkt and digital gold seem to be moving in lock step – expect our firm (Morgan Stanley) to play along and once involved market it ($BTC) as such.”

Interesting conversations yesterday that reveal how traditional market players and dealing with the growth of Bitcoin and crypto at large. The bigger picture, that these firms have finally embraced, is that Bitcoin isn’t going away. And they are hell-bent on being there when mass investment follows an increase in awareness and adoption.

FAKE NEWS: Fake Volumes On Crypto Exchanges Remain A Scourge On The Industry

Fake volumes are a problem at crypto exchanges across the spectrum. This practice is seemingly used to push a crypto exchange brand up the ranks of Coin MarketCap’s exchange volume rankings, providing more visibility to potential crypto traders and investors. BitWise figured out the sneaky scheme and put together a report to warn investors.

According to Bitwise, the exchanges that skirt the defined lines between the “real” and the “fake” were HitBTC, Huobi, and OKEx.

The firm’s March report addressed to the US Securities and Exchange Commission highlighted 10 exchanges with real volume. However, following public requests, the firm in a subsequent report highlighted three exchanges with “meaning volume”.

Firstly, the report analyzed the trade volume percentage on an exchange, depending on a specific trade size over a defined period. Citing this trade size histogram for OKEx, the report stated that the same is “notably suspicious,” as it had no absolute spikes and an “atypical rise” in volume from 1-6 BTC. The exchange’s trade distribution also showed an “unusual” tail from 6 Bitcoins.

In terms of volume spikes from 28 April to 5 May, the graph depicted constant hourly volume which according to Bitwise, “betrays none of the natural rhythms of the reference exchanges.” The “reference exchanges,” are the 10 exchanges that Bitwise has contended as having “real volume.”

If you happen to be scoring at home this opens up several lines of questions that could serve to potentially crash the markets in a similar way to Mt. Gox, should the truth eventually be found out.

Our advice: stick to the top four or five exchanges and avoid the potential for a ‘lose all your money’ type of event. Cryptopia we are looking at you.

BAKKT BAND: Executive Roll Grows; “Doubting this team would be foolish…”

Just yesterday Bakkt announced another high level executive that comes to the project with an impressive resume’ and credentials that can’t be assailed. After speaking with several sources (disclosure: these sources have an equity position in Bakkt), it is clear that many, if not most, believe Bakkt is a nearly ‘fail-proof’ venture.

Just look at the executives, investors, announced partners – and the numbers really begin to add up. Venture capital scions and other well capitalized names that have taken a stake in Bakkt view the firm and its growing staff as the ‘gold standard’ and unmatched in the crypto space. We understand why.

Executives that include Kelly Loeffler, Adam White, and now Mike Blandina formerly of PayPal and Google. A board consisting of Tom Noonan, Jeff Sprecher, Sean Collins, and Akshay Naheta. Investors that include Mike Novogratz at Galaxy Digital, Fortress Capital, Pantera Capital, Boston Consulting Group, Eagle Seven, M12 (Microsoft’s venture capital arm), Goldfinch Partners, and several others.

A literal who’s who of Fintech venture capital and superstar execs with their sights set squarely on leading crypto to the promised land of adoption and usage for the masses.

One source who’s invested in the firm said the following, “You can never guarantee a win in venture capital or any such endeavor; but the risk/reward profile is seriously tipped in our favor as stakeholders. The team is as good as it gets, the tech has been in place for the better part of a decade (ICE), and planning for this moment has been going on for nearly four years. Our thesis, doubting this team would be foolish, so we remain very comfortable with our investment.”

Microsoft, Starbucks, and a bevy of executives and investors with lengthy and proven histories in building brands, mass marketing, work flow, leadership and good ole’ fashioned winning.

As a business it is a recipe for phenomenal success. As a marketing entity, and how it relates to crypto at large, Bakkt is on a mission to make spending and trading crypto as ubiquitous as credit cards and online brokerage houses.

Expect a marketing blitz that is smart and ever expanding. Bakkt is certainly planning on it being a large part of its eventual (inevitable) success.

REPORT: NEW YORK CRYPTO REGULATIONS: NY BitLicense Is An Abomination; May Only Get Worse

New York, one of the first states to adopt virtual currency rules, has taken a relatively strict approach in the regulation of virtual currency activities.1 The rules, enacted on 24 June 2015, established a regulatory framework for virtual currency businesses that requires operations related to transactions involving any form of virtual currency to obtain a “Bitlicense” from the state.2

The strict licensing requirements favor large virtual currency firms and financial institutions. The BitLicense application and licensing process are likely overly burdensome for small companies with limited access to capital and legal resources.

Overview of Bitlicense

Subject to certain exceptions, anyone engaging in any of the following activities is required to obtain a BitLicense from the New York State Department of Financial Services (“NYSDFS”):

  • Virtual currency transmission
  • 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
  • Controlling, administering, or issuing a virtual currency.3

Out-of-state businesses that engage in virtual currency activity involving New York State, or with persons within the state, must obtain a BitLicense to conduct their business.4

Some of the regulatory requirements include:

  • Minimum capital reserves
  • Records of transactions must be kept for at least seven years
  • Quarterly financial statements must be submitted within 45 days of the close of a quarter
  • Background checks on all employees must be performed by an independent investigatory agency
  • Appointment of a dedicated compliance officer
  • Enforcement of written anti-fraud, anti-money laundering, cybersecurity, privacy, and information security procedures
  • Prior written approval from the superintendent of the NYSDFS before the company introduces a “material change” to their business models, such as a new product or service
  • Prior written approval from the superintendent of the NYSDFS before any merger with or acquisition of any company holding a BitLicense5

The application fee for a Bitlicense is $5000 and the applicant must complete a 31-page application form.6

The “one-size-fits-all” licensing process does not provide any exceptions for small virtual currency companies.

Application Approval Process Slow, but Improving

The 2015 rules do not impose a deadline on the NYSDFS for completing the licensing process.7

Since the enactment of the rules, the NYSDFS has approved only eleven charters or licenses for virtual currency companies.8

The license for Genesis Global Trading was not granted for nearly three years, and a license for BitFlyer USA, Inc. was not granted for over a year.9

The number of licenses issued will likely increase over the next 12-24 months.

Focus Remains on Consumer Protection: The 2018 New York Attorney General Report

In September, the New York Attorney General (“NYAG”) issued a report that concluded crypto trading platforms vary significantly in their risk management strategies and in the ways they fulfill customer responsibilities.10

The NYAG identified three broad areas of concern: potential conflicts of interest; lack of serious efforts to impede abusive trading activity; and limited protections for customer funds.11

The NYAG also referred three virtual currency exchanges- Kraken, Binance, and Gate.io-to the state’s financial regulator for possible legal action and raised concerns over price manipulation and conflicts of interest on trading platforms.12

The report concludes that “virtual asset trading platforms have yet to implement serious efforts to monitor and stop abusive or manipulative trading.”13

Draft Virtual Currency Legislation Introduced into the State Assembly

Virtual currency bills have been introduced in the State Assembly this year. New York, however, will not likely amend existing rules or introduce major virtual currency legislation until 2020, after the State Assembly is able to review a task force report that must be completed by December 2019.

  • Bill on the Creation of Virtual Currency Task Force: The bill proposes the creation of a digital currency task force to provide the governor and the legislature with information on the potential effects of the widespread implementation of digital currencies on financial markets in the state. If passed, the bill would establish a group consisting of nine members which would be called on to submit a report to the governor, temporary president of the Senate, and the speaker of the assembly by December of 2019. Additionally, the task force would be required to provide the number of digital currencies and exchanges operating in the state, information about large investors in the field, and the energy consumption necessary for coin mining operations. The task force would also provide a review of laws and regulations on digital currency used by other states, the federal government, foreign countries, and foreign political and economic unions to regulate the marketplace.14
  • strong>Bill on Virtual Currency: The bill proposes eliminating the BitLicense and licensing fees. In addition, the bill mandates that any virtual currency business or entity be subject to routine audits by a public or third-party depository service. Any entity in full compliance will receive a digital New York Seal of Approval to reassure consumers that the outlet is trustworthy and secure.15

Recommendation: We would advise new crypto firms to consider establishing operations in Montana, New Hampshire, Texas, Tennessee or Wyoming.

The information provided in this report is for informational purposes only. It should not be considered legal or financial advice. You should consult with an attorney, financial advisor, or other professional to determine what may be best for your individual needs.


This report was prepared by Trifin Roule.

For nearly two decades, Mr. Roule provided for the U.S. government legal analysis of anti-money laundering, counterproliferation financing and counterterrorist financing laws and regulations dozens of jurisdictions, and international standards, as detailed through intergovernmental bodies (e.g. Financial Action Task Force (FATF)), and financial institutions (e.g. banks’ financial intelligence units and compliance offices).

In addition, Mr. Roule has provided in-depth analysis of digital asset accounting, auditing, customer due diligence, exchange, licensing, mining, initial coin offering (ICO), private key storage, and record-keeping practices and regulations.

Mr. Roule is a former Assistant Editor at the Journal of Money Laundering Control, a peer-reviewed journal that provides detailed analysis and insight on the latest issues in the law, regulation and control of money laundering and related matters. Mr. Roule has published dozens of articles on anti-money laundering, and counterterrorist financing laws and regulations.

Trifin Roule is the Publisher of our new division, Abacus Legal, and his and his team’s reports will be free to read for the next 45 days. After that time they will be dubbed premium content and require a subscription.


  1. “New York State Department of Financial Services, New York Codes, Rules and Regulations, Title 23, Department of Financial Services, Chapter I, Regulations of the Superintendent of Financial Services, Part 200. Virtual Currencies”.
  2. In accordance with the New York State Administrative Procedure Act (SAPA), the final DFS rules for virtual currency business activity have been published in the New York State Register’s June 24, 2015 edition.
  3. New York Codes, Rules and Regulations, Title 23, Department of Financial Services, Chapter I, Regulations of the Superintendent of Financial Services, Part 200: Virtual Currencies, §200.2(q).
  4. New York Codes, Rules and Regulations, Title 23, Department of Financial Services, Chapter I, Regulations of the Superintendent of Financial Services, Part 200: Virtual Currencies, §200.2(q).
  5. New York Codes, Rules and Regulations, Title 23, Department of Financial Services, Chapter I, Regulations of the Superintendent of Financial Services, Part 200: Virtual Currencies, §§200.4, 200.7.-200.19.
  6. New York Codes, Rules and Regulations, Title 23, Department of Financial Services, Chapter I, Regulations of the Superintendent of Financial Services, Part 200: Virtual Currencies, §200.5; and “Application Forms For: License to Engage in Virtual Currency Business Activity,” New York Department of Financial Services at URL: https://www.dfs.ny.gov/legal/regulations/vc_license_application.pdf.
  7. New York Codes, Rules and Regulations, Title 23, Department of Financial Services, Chapter I, Regulations of the Superintendent of Financial Services, Part 200: Virtual Currencies, §200.3.
  8. “DFS Authorizes Coinbase Global, Inc. to Form Coinbase Custody Trust Company LLC,” New York Department of Financial Services Press Release at URL: https://www.dfs.ny.gov/about/press/pr1810231.htm.
  9. “The Ledger: Is New York’s BitLicense an ‘Absolute Failure?” Fortune, 25 May 2018.
  10. “Virtual Markets Integrity Report – New York State Attorney General,” Office of the New York State Attorney General, 18 September 2018, p. 1.
  11. “Virtual Markets Integrity Report – New York State Attorney General,” Office of the New York State Attorney General, 18 September 2018, pp. 5-6.
  12. “Virtual Markets Integrity Report – New York State Attorney General,” Office of the New York State Attorney General, 18 September 2018, p. 2.
  13. “Virtual Markets Integrity Report – New York State Attorney General,” Office of the New York State Attorney General, 18 September 2018, p. 5.
  14. Bill No. S09013: Creates the digital currency task force to provide the governor and the legislature with information on the potential effects of the widespread implementation of digital currencies on financial markets in the state, New York State Assembly website at URL: https://nyassembly.gov/leg/?bn=S09013&term=2017.
  15. Bill No. A09899: Relates to financial technology products and services; establishes a regulatory sandbox program, New York State Assembly website at URL: https://nyassembly.gov/leg/?default_fld=%250D%250A&leg_video=&bn=A9899&term=2017&Summary=Y&Actions=Y&Committee%2526nbspVotes=Y&Floor%2526nbspVotes=Y&Text=Y.