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Early this morning, NYDFS proposed an update to the BitLicense that would permit license holders to self-certify new assets for addition to their services. This is a solid step in the right direction. Analysis follows
2/ Some historical context is worthwhile here. The original BitLicense came under fire for requiring "permission to innovate". Among other requirements, licenseholders were obligated to ask DFS' permission before adding any new asset.
3/ The practical challenges this created were foreseeable in character, if not in magnitude. Back in 2013-2014, when the proposal was first discussed, there were, well, not so many coins.
4/ Once the Cambrian explosion of 2016/17 hit, this requirement went from intellectually frustrating to downright impractical. My clients at the time found this to be the most cumbersome element of the then-fledgling license. They wanted to list hundreds of coins, not just a few
5/ Looking under the hood: The requirement demanded a perverse sort of min-maxing. How should a *new* applicant seek approval to list all 100 assets it already knows it wants to add? ...
6/ Should it list all of them on its initial application and wait a lifetime for DFS to approve the application? Or, should it only list a few on the initial application, hope for speedy approval, and then immediately follow up with a list of 99 new assets for approval?
7/ There was a less practical, more principled concern at play, too: How on earth was NYDFS supposed to know which assets were "good" and which were "bad"?
8/ When confronted with this type of issue, regulators have often taken the position that, though they could make this determination, industry participants were better placed to do so. Sound familiar? Maybe because this is precisely how AML laws work.
9/ The global standard for AML relies on the basic principle that a business knows its business best. So, the right approach is not to require adherence to prescriptive rules, but instead to require that each business conduct an analysis of the risks it faces.
10/ This is called the "risk-based-approach" and, though it has its drawbacks, is just about the best thing we've got to address these kinds of harms. Good on DFS for adopting it here. The text, for those interested: https://www.dfs.ny.gov/apps_and_licensing/virtual_currency_businesses/pr_guidance_regarding_listing_of_vc …
It's about time, great news!
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