Robinhood Resolution a First for Cryptocurrency Enforcement in NY

Compliance officers looking for helpful “ripped-from-the-headlines” enforcement actions to support their requests for resources and direct access to the board need look no further than the recent $30‑million fine from the New York Department of Financial Services (NYDFS) on the cryptocurrency trading unit of online brokerage firm Robinhood Markets, Inc. The consent order for the NYDFS’ first crypto enforcement action describes deficiencies in the compliance culture; violations of a host of virtual currency, anti-money laundering, Bank Secrecy Act, financial services and cybersecurity regulations; and Robinhood’s hyper-fast growth and reliance on its parent company’s (also inadequate) compliance systems and resources as potential factors in its failures. This article discusses the alleged failures and provides commentary on the consent order’s implications from partners at Skadden and Greenberg Traurig. See “Navigating the Intersection of Digital Assets and AML” (Jul. 21, 2022).

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