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<ul class="summary-list"><li>A father and son team of computer programmers help people find lost passwords to their <keyword id="11893898" type="UNKNOWN" weightage="60" keywordseo="crypto" source="Orion">crypto</keyword> wallets. </li><li>Chris and Charlie Brooks conducted an analysis that led them to estimate between 68,110 and 92,855 seemingly lost bitcoins are recoverable.</li><li>At current prices, the high end of the <keyword id="12025864" type="UNKNOWN" weightage="60" keywordseo="recoverable-bitcoin" source="Orion">recoverable bitcoin</keyword> estimate amounts to $4.7 billion. </li></ul>For Chris and Charlie Brooks, finding lost passwords to cryptocurrency wallets requires figuring out how their clients' minds work - and that effort can help their customers retrieve a slice of what the pair estimates is about $4.7 billion worth of recoverable <keyword id="11893902" type="UNKNOWN" weightage="60" keywordseo="bitcoin" source="Orion">bitcoin</keyword> stranded in locked wallets. "We get a really broad spectrum of clients. We have a client who is an early-stage miner in bitcoin who lost all of his information and he knows he's got some bitcoins somewhere … We get clients who were told in 2017 to buy into the hype-bubble and they bought $1,000 [worth] and they are looking for something to cover the rent," Charlie, a 20-year-old computer programmer who joined his father in running <a href="https://cryptoassetrecovery.com/">Crypto Asset Recovery</a> based in New Hampshire, told Insider in a video interview. "One of our most recent cracks had about $250,000," in a blockchain wallet, said Charlie, who majored in computer science in college. He's put school aside for now to work at the business. "This is something I've always liked. I would follow along with my dad ... Online treasure hunting, it seemed really cool." Nearly 40% of 1,000 US crypto owners in a recent <a href="https://www.cryptovantage.com/cryptocurrency-storage-security/">survey from Cryptovantage</a> said they had lost wallet passwords and, on average, those unable to find their passwords lost $2,134. The jumping-off point of the duo's estimate of what can be recovered was a Chainalysis estimate that up to 20% of 18.5 million existing bitcoin appear to be lost or stranded in locked wallets. The figures were cited in January by <a href="https://www.nytimes.com/2021/01/12/technology/bitcoin-passwords-wallets-fortunes.html?searchResultPosition=2">The New York Times in a story about a San Francisco-based programmer</a> who couldn't find the password to the hard drive that stored his 7,002 bitcoin. <a href="https://www.businessinsider.com/bitcoin-owner-who-lost-password-made-peace-potentially-huge-loss-2021-1">After eight wrong guesses, he had two left</a> to figure out the password before the virtual currency was likely lost forever. The Chainalysis figure sparked a question for the Brookses."Yes, that bitcoin is lost but if the owner of that bitcoin were motivated, what percentage of those do we think is reasonable to assume could be recovered?," said Chris, a 50-year-old computer programmer who started his business in 2017 and, after some time retooling, ramped up operations late last year when his son came on board. Nakamoto's forum To find a sample of <keyword id="12025865" type="UNKNOWN" weightage="60" keywordseo="lost-bitcoin" source="Orion">lost bitcoin</keyword> for their analysis, Chris said they turned to a thread on BitcoinTalk, a forum whose creation is credited to bitcoin inventor Satoshi Nakamoto. A thread started in 2011 called "<a href="https://bitcointalk.org/index.php?topic=7253.0">Let's add up the KNOWN lost bitcoins</a>" is filled with posts by people with the amount of bitcoin they lost and how it happened. The Brookses filtered and set parameters on the information, such as excluding losses of less than half of a bitcoin, to make an estimate on the sample population of the bitcoin reported lost. The Brookses narrowed it all down to 72 posts that described the loss of at least half of a bitcoin. They determined that 14% are potentially recoverable cases and that from their own work in recovering wallets for clients, they can decrypt about 35% of passwords. That led to their conclusion that about 2.45% of lost bitcoin is retrievable. With a range between 68,110 and 92,855 bitcoins, that would make up to $4.7 billion in bitcoin recoverable based on the asset's price of about $50,372 on Friday. Good guesses "We get as good a list of passwords as we can from a client and then we put our heads together and spend some time extrapolating the way that they make their passwords and try to get in their mind when they are actually creating a password," said Charlie. "That's the most helpful thing, just seeing their practice," he said. "That's the cornerstone of our business, essentially." The duo will run "hundreds of millions or billions of variations" of password patterns and test those against the encrypted version of the wallet, said Chris. "If you don't have a very good [password] guess, there are more possible passwords than there are atoms in the universe, and I'm not being facetious when I say that," Chris said.The Brookses said decrypting times vary but occasionally can take as little as five seconds. That happened with a client whose list of nine potential passwords contained the correct one. Charlie said they worked for roughly a month and a half with the client who turned out to have about $250,000 in his wallet. Security measures they take include having clients sign a contract stating they are the owner of the blockchain wallet being worked on. The two get paid on a sliding scale. Starting with wallets containing between zero and 10 bitcoins, or an equivalent value, the team will earn a 20% commission. There's no charge to clients if they can't recover any funds. Chris said a number of their clients live in countries where people are largely unbanked."They may have a wallet with a couple of hundreds of dollars in it and that is their life savings. If they lose the password to it, they have no access to it anymore," said Chris. "In some sense, it can be a heartbreaking piece of the business … we do crack some of [the wallets]. It's a balancing act to be helpful without going too far down a rabbit hole."

A father and son who help clients find forgotten crypto passwords estimate billions of dollars worth of lost bitcoin is recoverable

<ul class="summary-list"><li><keyword id="6354947" type="UNKNOWN" weightage="60" keywordseo="bitcoin">Bitcoin</keyword> slipped 10.8% in the 24 hours to Sunday morning.</li><li>It was the biggest single-day drop since February, Bloomberg reported.</li><li>Reports attributed the drop to speculation the US Treasury may scrutinize digital currencies closer. </li></ul>Bitcoin tumbled to its biggest single-day drop since February over Saturday, just days after reaching a record high, <a href="https://www.bloomberg.com/news/articles/2021-04-18/bitcoin-falls-as-much-as-15-biggest-intraday-drop-since-feb">Bloomberg reported. </a>Bitcoin fell 10.8% in the 24 hours to Saturday 7am ET, from $61,396 to $54,750. At one point, it reached a low of $51,300 after it dropped more than $7,000 in a single hour, before partially recovering.Several online outlets attributed the drop to speculation the US Treasury may take action against money laundering conducted through digital assets,<a href="https://www.bloomberg.com/news/articles/2021-04-18/bitcoin-falls-as-much-as-15-biggest-intraday-drop-since-feb"> per Bloomberg</a> and <a href="https://www.coindesk.com/bitcoin-price-falls-8k-to-3-week-low-altcoins-crash">Coinbase</a>.Bitcoin hit a record high of $64,869.78 <a href="https://markets.businessinsider.com/currencies/news/bitcoin-price-record-high-coinbase-direct-listing-btc-crypto-2021-4-1030302632">on Wednesday</a> ahead of the stock-market debut for the <keyword id="6357017" type="DEFINITION" weightage="60" keywordseo="cryptocurrency">cryptocurrency</keyword> exchange <a href="https://markets.businessinsider.com/currencies/news/coinbase-ipo-watershed-moment-cryptocurrencies-cryptocom-bitcoin-2021-4-1030314877">Coinbase Global Inc. on the Nasdaq</a>. Bitcoin has faced more regulatory scrutiny in recent months. Turkey's central bank said on Friday that it would cease the use of cryptocurrencies as a valid form of payment from April 30. The move <a href="https://markets.businessinsider.com/currencies/news/bitcoin-price-today-turkey-central-bank-crypto-payment-ban-lira-2021-4-1030313525">caused Bitcoin to slip as much as 5%.</a> The bank said the anonymity of digital brings the risk of "non-recoverable" losses. In March, <a href="https://www.businessinsider.com/india-clamps-down-on-crypto-ecommerce-players-2021-3?r=US&amp;IR=TIR=T">Insider reported</a> that India was likely to ban bitcoin and fine anyone who buys, holds, or sells any form of digital currency.While concerns linger over the risks associated with bitcoin, some companies are embracing the cryptocurrency: <a href="https://www.businessinsider.com/more-companies-accepting-bitcoin-cryptocurrency-paypal-starbucks-2021-4?r=US&amp;IR=TIR=T">Paypal and Xbox</a>, for example, are beginning to accept bitcoin as payment, and Wall Street firms such as Morgan Stanley are considering stakes in the digital token so they can give their wealthiest clients access to the <keyword id="2721952" type="PERSON" weightage="60" keywordseo="crypto">crypto</keyword> market.

Bitcoin plummets more than 10% in its biggest drop in months, just days after reaching a record high

<ul class="summary-list"><li><keyword id="6354947" type="UNKNOWN" weightage="60" keywordseo="bitcoin">Bitcoin</keyword> slipped as much as 5% Friday after reports that Turkey has banned the use of <keyword id="2420795" type="PERSON" weightage="60" keywordseo="cryptocurrencies">cryptocurrencies</keyword>.</li><li>The move stoked fear among investors of a precedent that other countries may follow.</li><li>Cryptocurrencies have become popular in Turkey as a hedge against the lira.</li></ul>Bitcoin slipped as much as 5% from record highs on Friday after amid reports that Turkey's central bank will bar the use of cryptocurrencies as a method of payment starting April 30. The move stoked fears that other nations may follow suit.Bitcoin tumbled 5.3%, to $60,062.71, at intraday lows. Altcoins such as ether and XRP also slipped as they typically move in lockstep with the world's biggest cryptocurrency.Turkey's central bank on Friday said <a href="https://www.tcmb.gov.tr/wps/wcm/connect/EN/TCMB+EN/Main+Menu/Announcements/Press+Releases/2021/ANO2021-17">crypto assets entail significant risks</a>, citing four reasons: lack of regulatory oversight, volatility of market valuation, possible use for illegal transactions, and the fact that these transactions are irrevocable."It is considered that their use in payments may cause non-recoverable losses for the parties to the transactions due to the above-listed factors," the bank said in a statement. "And they include elements that may undermine the confidence in methods and instruments used currently in payments."David Wachsman, founder and CEO of Wachsman - a global strategy firm that specializes in cryptocurrency and blockchain - said Turkey's move to ban crypto payments impacts bitcoin primarily from a macroeconomic investment perspective."It implies that other countries might follow suit if they see bitcoin or other cryptocurrencies as a threat," he said. "Moreover, Turkey on its own has had a surprising and burgeoning crypto scene over the last few years, so the fact that 82 million people may have reduced access to bitcoin is a blow in and of itself."Read more: <a href="https://www.businessinsider.com/bitcoin-contango-offers-risk-free-high-return-trade-opportunity-futures-2021-4" target="_blank" rel="noopener">Bitcoin is a headache to store, and that's created an investment opportunity that could theoretically pay determined traders big risk-free returns by December</a>Cryptocurrencies have picked up steam in Turkey in the past weeks as investors sought various hedges against the unstable lira. Just this week, the company that distributes Rolls-Royce in Turkey - Royal Motors - became the first business in the country to accept payments in cryptocurrencies, <a href="https://www.reuters.com/technology/turkey-bans-use-cryptocurrencies-payments-sends-bitcoin-down-2021-04-16/">Reuters first reported</a>.In March, the country's currency found itself in turmoil after the <a href="https://www.reuters.com/article/us-turkey-cenbank-governor/turkish-lira-plunges-after-erdogan-sacks-hawkish-central-bank-chief-idUSKBN2BD0BB">dismissal of Naci Agbal</a>, Turkey's central bank chief, which took many by surprise. The lira <a href="https://markets.businessinsider.com/news/stocks/turkish-lira-markets-president-erdogan-sacks-central-bank-chief-inflation-2021-3-1030231437">tumbled 14% to a near all-time low</a> following the news.But Viktor Prokopenya, a London-based Fintech investor, said the move of Turkey was not surprising."Turkey is a very centralized and authoritarian state, which has very little desire to make decentralized technologies," he said. "Having said that, the stance of governments changes all the time towards crypto, but the individual opinions of small countries don't matter that much. The biggest risk to crypto comes from US regulators."Bitcoin this week hit record highs, <a href="https://markets.businessinsider.com/currencies/news/bitcoin-price-record-high-coinbase-direct-listing-btc-crypto-2021-4-1030302632">inching close to $65,000</a>, ahead of excitement over <keyword id="1972612" type="PERSON" weightage="60" keywordseo="Coinbase">Coinbase</keyword>'s listing on the Nasdaq, signifying a milestone for the broader digital currency ecosystem.

Bitcoin tumbles 5% from record highs amid Turkey's crypto-payments ban starting April 30

<ul class="summary-list"><li>A second <keyword id="6119275" type="UNKNOWN" weightage="60" keywordseo="cryptocurrency-exchange">cryptocurrency exchange</keyword> has collapsed in <keyword id="6372909" type="LOCATION" weightage="60" keywordseo="turkey">Turkey</keyword>, adding to the country's crypto woes.</li><li>Analysts said the abrupt closure of the exchanges highlighted the risks of <keyword id="2420795" type="PERSON" weightage="60" keywordseo="cryptocurrencies">cryptocurrencies</keyword>.</li><li>Many have turned to <keyword id="6354947" type="UNKNOWN" weightage="60" keywordseo="bitcoin">bitcoin</keyword> and other assets to try to hedge against the country's high inflationn rate.</li></ul>The <keyword id="5290028" type="UNKNOWN" weightage="60" keywordseo="cryptocurrency-market">cryptocurrency market</keyword> has been dealt a major blow in Turkey after a second exchange went down on Friday. The closures have left hundreds of thousands of people without access to <a href="https://markets.businessinsider.com/currencies/btc-usd">bitcoin</a> and other assets, which many had bought as a hedge against rampant inflation.Analysts said the events were a reminder to cryptocurrency investors everywhere to be sure to do business with reputable companies.Vebitcoin, a Turkish crypto exchange which had around $60 million in daily trading volumes, announced it had stopped all of its activities on Friday. It put a message up on its <a href="https://www.vebitcoin.com/">website</a> blaming financial strains.The Turkish financial crimes watchdog then blocked all the exchange's bank accounts in the country later that day, according to the state-run <a href="https://www.aa.com.tr/en/economy/turkey-blocks-bank-accounts-of-vebitcoin/2218712">Anadolu news agency</a>.Vebitcoin's announcement came days after rival Turkish crypto exchange Thodex <a href="https://markets.businessinsider.com/currencies/news/thodex-massive-crypto-losses-ceo-missing-istanbul-crypto-exchange-2021-4-1030333822">stopped operations</a> and its founder fled the country. The exchange had around 390,000 active users, according to reports.The abrupt closure of the exchange was one catalyst for bitcoin's dramatic <a href="https://markets.businessinsider.com/currencies/news/bitcoin-price-outlook-btc-joe-biden-tax-derivatives-support-2021-4-1030338710">fall below $50,000</a> from recent highs close to $65,000, analysts said."The collapse of two exchanges in Turkey sent a warning to many cryptocurrency traders who have gotten into crypto with unreputable companies," Edward Moya, senior market analyst at Oanda, said.Turkey's cryptocurrency woes have been tied up with government efforts to crack down on the market.Last week the country's central bank backed a <a href="https://markets.businessinsider.com/currencies/news/turkey-ban-cryptocurrencies-payment-bitcoin-lira-ether-crypto-digital-asset-2021-4-1030311899">ban on crypto payments</a>. It said using cryptocurrencies for payments could cause "non-recoverable losses" for the parties involved.But many Turks have turned to cryptocurrencies as a hedge against inflation, which stood at 16.2% in March."People like the idea of cryptocurrencies because they're unconstrained by the government," Marshall Gittler, head of investment research at BDSwiss, said. "But that freedom comes with costs - it also means there's no insurance and limited regulation."Philip Gradwell, chief economist at Chainalysis, said: "The troubles at Turkish exchanges illustrate the importance of clear and stable regulation for cryptocurrency."He added: "Investors in the USA and Europe are fortunate to have reputable cryptocurrency exchanges that operate within a strong regulatory framework, so the events in Turkey should not reduce their confidence."

Turkey's cryptocurrency nightmare worsened after a second exchange collapsed - stoking fears about bitcoin's risks

<ul class="summary-list"><li>The Turkish central bank announced a ban on use of <keyword id="2721952" type="PERSON" weightage="60" keywordseo="crypto">crypto</keyword> assets as payment. </li><li>People will be able to own <keyword id="2420795" type="PERSON" weightage="60" keywordseo="cryptocurrencies">cryptocurrencies</keyword>, but not use them from April 30. </li><li>Crypto has become increasingly popular in <keyword id="6372909" type="LOCATION" weightage="60" keywordseo="turkey">Turkey</keyword> as the <keyword id="311688" type="PERSON" weightage="60" keywordseo="Lira">lira</keyword> weakened and inflation has risen.</li></ul>The Turkish central bank said on Friday it would ban the use of cryptocurrencies as a form of payment, effective from April 30. The new regulations do not stop Turkish citizens from holding crypto assets. Under the new regulations, consumers won't be able to use crypto assets to pay for goods and services, or in exchange for payment services, or the issuance of electronic money. This means that payment-service providers will no longer be allowed to offer customers any products that are linked to crypto assets, or allow crypto assets as a payment option. In recent months, various large financial services providers including Visa, Mastercard and PayPal announced they would be opening their networks and infrastructure to support payments made with digital assets. The new regulation also stops crypto exchanges from operating in Turkey, limiting their customer base. Banks operating in the country will also not be permitted to develop crypto-based products or invest in them. The central bank cited a lack of regulatory authority, high volatility, the use of crypto assets to fund illegal activities, crypto wallets being unlawfully used, or stolen, and the irrevocable nature of transactions as reasons for the ban. It said these risks were too high for all parties involved. After a recent push towards crypto assets, "It is considered that their use in payments may cause non-recoverable losses for the parties to the transactions due to the above-listed factors and they include elements that may undermine the confidence in methods and instruments used currently in payments", according to a <a href="https://www.tcmb.gov.tr/wps/wcm/connect/EN/TCMB+EN/Main+Menu/Announcements/Press+Releases/2021/ANO2021-17">statement</a> by the Turkish central bank. Last month, the former Turkish central bank chief Naci Agbal was sacked by President Recep Tayyip Erdogan after raising interest rates, an economic policy commonly used to lower inflation. The rate of inflation in Turkey topped 16% in March. The Turkish lira fell by as much as 14% against the dollar following Agbal's removal as central bank chief and has barely recovered since. Erdogan and Agbal's successor Sahap Kavcioglu believe higher interest rates drive up inflation. Despite this, rates were left unchanged at Kavcioglu's first policy meeting on Thursday. In recent months, cryptocurrencies have surged in popularity in Turkey. Trading volumes spiked as Turkish citizens were concerned about their savings losing value if stored in lira, <a href="https://www.reuters.com/article/crypto-currency-turkey-int-idUSKBN2BN1FO?taid=60649c929e71f30001ce205d&amp;utm_campaign=trueAnthem:+Trending+Content&amp;utm_medium=trueAnthem&amp;utm_source=twitterurce=twitter">Reuters reported</a>. Major cryptocurrencies, including <keyword id="6354947" type="UNKNOWN" weightage="60" keywordseo="bitcoin">bitcoin</keyword> and <keyword id="6709758" type="UNKNOWN" weightage="60" keywordseo="Ether">ether</keyword>, fell following the news from Turkey. Both had previously reached record highs this week. On Friday, bitcoin traded at $60,594.33, down around 4% on the day, while Ethereum's ether was down almost 3%, trading around $2,385.34.

Turkey says it will ban the use of cryptocurrencies as a form of payment

<div class="KonaFilter image-container display-table float_right"><div><div class="image">REUTERS/Lucas Jackson</div></div></div>The New York Department of Financial Services has released a draft for what the state's BitLicenses will look like, and they're going to change the face of Bitcoin in the U.S..
The greatest change is that anyone using a New York-sanctioned Bitcoin service will no longer be anonymous. This was something Bitcoin's earliest users said was essential to the digital currency's appeal, but which DFS, as well as other lawmakers, expressed strong distaste for at hearings earlier this year.
Now, any business whose essential service is buying, selling, or processing Bitcoin will have to maintain records of their customers' names and addresses, and check them against the Treasury's list of bad actors.
They'll also have to maintain reserve Bitcoin assets equal to 100% of however much they are holding on behalf of customers, and get bonded-up "in such form and amount as is acceptable to DFS for the protection of the licensee's customers." And they'll have to submit and publish a detailed consumer complaint policy that must include a provision allowing customers to pursue their complaint with DFS.
The draft proposal makes New York the first government entity to propose comprehensive Bitcoin regulations, and are likely to serve as a model for other states and even federal guidelines, given New York's role as the vanguard financial authority outside Washington - DFS Superintendent Ben Lawsky, for instance, was a critical player in the recent penalties delivered against BNP Paribas for violating sanctions. 
You won't need a license if you're a retailer accepting Bitcoin or other cryptocurrencies as a form of payment.
Here's the full text:
NY DFS RELEASES PROPOSED BITLICENSE REGULATORY FRAMEWORK FOR VIRTUAL CURRENCY FIRMS 
Framework Includes Consumer Protection, Anti-Money Laundering, and Cyber Security Rules for Virtual Currency Businesses 
 
Proposed Regulations Submitted for a 45-Day Notice and Comment Period to Solicit Public Feedback 
Benjamin M. Lawsky, Superintendent of Financial Services, today announced that the New York State Department of Financial Services (DFS) has issued for public comment a proposed "BitLicense" regulatory framework for New York virtual currency businesses. The proposed regulatory framework - which is the product of a nearly year-long DFS inquiry, including public <a href="http://www.dfs.ny.gov/about/hearings/vc_01282014_indx.htm" target="_blank">hearings</a> that the Department held in January 2014 - contains consumer protection, anti-money laundering compliance, and cyber security rules tailored for virtual currency firms. Superintendent Lawsky said: "We have sought to strike an appropriate balance that helps protect consumers and root out illegal activity - without stifling beneficial innovation. Setting up common sense rules of the road is vital to the long-term future of the virtual currency industry, as well as the safety and soundness of customer assets." 
In accordance with the New York State Administrative Procedures Act (SAPA), the proposed DFS rules for virtual currency firms will be published in the New York State Register's July 23, 2014 edition, which begins a 45-day public comment period. After that public comment period, the rules are subject to additional review and revision based on that public feedback before DFS finalizes them. Additionally, DFS is today immediately publishing a copy of the regulations on the website Reddit. Earlier this year, Superintendent Lawsky hosted an "Ask Me Anything" <a href="http://www.reddit.com/r/IAmA/comments/1ygcil/as_requested_im_ben_lawsky_superintendent_of_the" target="_blank">forum</a> on Reddit about DFS' work on virtual currency regulation, which generated more than 1,200 public comments. Links to the proposed rules are also being tweeted out from the DFS Twitter handle (@NYDFS) and Superintendent Lawsky's Twitter handle (@BenLawsky). Superintendent Lawsky said: "We recognize that - as the first state to put forward specially tailored rules for virtual currency firms - continued public feedback will be an important part of finalizing this regulatory framework. We look forward to carefully and thoughtfully reviewing public comments on our proposal."
 
The new DFS BitLicenses will be required for firms engaged in the following virtual currency businesses: 
<ul>
<li>Receiving or transmitting virtual currency on behalf of consumers;</li>
<li>Securing, storing, or maintaining custody or control of such virtual currency on the behalf of customers;</li>
<li>Performing retail conversion services, including the conversion or exchange of Fiat Currency or other value into Virtual Currency, the conversion or exchange of Virtual Currency into Fiat Currency or other value, or the conversion or exchange of one form of Virtual Currency into another form of Virtual Currency;</li>
<li>Buying and selling Virtual Currency as a customer business (as distinct from personal use); or</li>
<li>Controlling, administering, or issuing a Virtual Currency. (Note: This does not refer to virtual currency miners.) </li>
</ul>
The license is not required for merchants or consumers that utilize Virtual Currency solely for the purchase or sale of goods or services; or those firms chartered under the New York Banking Law to conduct exchange services and are approved by DFS to engage in Virtual Currency business activity. 
 
Key requirements for firms holding BitLicenses include:
 
<ul>
<li>Safeguarding Consumer Assets. Each firm must hold Virtual Currency of the same type and amount as any Virtual Currency owed or obligated to a third party. Companies are also prohibited from selling, transferring, assigning, lending, pledging, or otherwise encumbering assets, including Virtual Currency, it stores on behalf of another person. Each licensee must also maintain a bond or trust account in United States dollars for the benefit of its customers in such form and amount as is acceptable to DFS for the protection of the licensee's customers. </li>
<li>Virtual Currency Receipts. Upon completion of any transaction, each firm shall provide to a customer a receipt containing the following information: (1) the name and contact information of the firm, including a telephone number established by the Licensee to answer questions and register complaints; (2) the type, value, date, and precise time of the transaction; (3) the fee charged; (4) the exchange rate, if applicable; (5) a statement of the liability of the Licensee for non-delivery or delayed delivery; (6) a statement of the refund policy of the Licensee. </li>
<li>Consumer Complaint Policies. Each firm must establish and maintain written policies and procedures to resolve consumer complaints in a fair and timely manner. The company must also provide notice to consumers, in a clear and conspicuous manner, that consumers can bring complaints to DFS's attention for further review and investigation. </li>
<li>Consumer Disclosures. Companies must provide clear and concise disclosures to consumers about potential risks associated with virtual currencies, including the fact that: transactions in Virtual Currency are generally irreversible and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable; the volatility of the price of Virtual Currency relative to Fiat Currency may result in significant loss or tax liability over a short period of time; there is an increased risk of loss of virtual currency due to cyber attacks; virtual currency is not legal tender, is not backed by the government, and accounts and value balances are not subject to FDIC or SIPC protections; among others. </li>
<li>Anti-money Laundering Compliance. As part of its anti-money laundering compliance program, each firm shall maintain the following information for all transactions involving the payment, receipt, exchange or conversion, purchase, sale, transfer, or transmission of Virtual Currency: (1) the identity and physical addresses of the parties involved; (2) the amount or value of the transaction, including in what denomination purchased, sold, or transferred, and the method of payment; (3) the date the transaction was initiated and completed, and (4) a description of the transaction. </li>
</ul>
o Verification of Accountholders. Firms must, at a minimum, when opening accounts for customers, verify their identity, to the extent reasonable and practicable, maintain records of the information used to verify such identity, including name, physical address, and other identifying information, and check customers against the Specially Designated Nationals ("SDNs") list maintained by the U.S. Treasury Department's Office of Foreign Asset Control ("OFAC"). Enhanced due diligence may be required based on additional factors, such as for high-risk customers, high-volume accounts, or accounts on which a suspicious activity report has been filed. Firms are also subject to enhanced due diligence requirements for accounts involving foreign entities and a prohibition on accounts with foreign shell entities. 
o Reporting of Suspected Fraud and Illicit Activity.Each Licensee shall monitor for transactions that might signify money laundering, tax evasion, or other illegal or criminal activity and notify the Department, in a manner prescribed by the superintendent, immediately upon detection of such a transactions. When a Licensee is involved in a transaction or series of transactions for the receipt, exchange or conversion, purchase, sale, transfer, or transmission of Virtual Currency, in an aggregate amount exceeding the United States dollar value of $10,000 in one day, by one Person, the Licensee shall also notify the Department, in a manner prescribed by the superintendent, within 24 hours. In meeting its reporting requirements Licensees must utilize an approved methodology when calculating the value of Virtual Currency in Fiat Currency. 
<ul>
<li>Cyber Security Program: Each licensee must maintain a cyber security program designed to perform a set of core functions, including: identifying internal and external cyber risks; protecting systems from unauthorized access or malicious acts; detecting systems intrusions and data breaches; and responding and recovering from any breaches, disruptions, or unauthorized use of systems. Among other safeguards, each firm shall also conduct penetration testing of its electronic systems, at least annually, and vulnerability assessment of those systems, at least quarterly.</li>
</ul>
 
<ul>
<li>Chief Information Security Officer. Each Licensee shall designate a qualified employee to serve as the Licensee's Chief Information Security Officer ("CISO") responsible for overseeing and implementing the Licensee's cyber security program and enforcing its cyber security policy.</li>
</ul>
 
<ul>
<li>Independent DFS Examinations: Examinations of licensees will be conducted whenever the superintendent deems necessary - but no less than once every two calendar years - to determine the licensee's financial condition, safety and soundness, management policies, and compliance with laws and regulations. </li>
<li>Books and Records: Licensees are required to keep certain books and records, including transaction information, bank statements, records or minutes of the board of directors or governing body, records demonstrating compliance with applicable laws including customer identification documents, and documentation related to investigations of consumer complaints. </li>
<li>Reports and Financial Disclosures, Audit Requirements. Each firm must submit to DFS quarterly financial statements within 45 days following the close of the Licensee's fiscal quarter. Each firm must also submit audited annual financial statements, prepared in accordance with generally accepted accounting principles, together with an opinion of an independent certified public accountant and an evaluation by such accountant of the accounting procedures and internal controls of the firm within 120 days of its fiscal year end. </li>
<li>Capital Requirements: Necessary capital requirements will be determined by DFS based on a variety of factors, including the composition of the licensee's total assets and liabilities, whether the licensee is already licensed or regulated by DFS, the amount of leverage used by the firm, the liquidity position of the firm, and extent to which additional financial protection is provided for customers. </li>
<li>Compliance Officer. Each Licensee shall designate a qualified individual or individuals responsible for coordinating and monitoring compliance with NYDFS' BitLicense regulatory framework and all other applicable federal and state laws, rules, and regulations. </li>
</ul>
 
<ul>
<li>Business Continuity and Disaster Recovery. Each Licensee shall establish and maintain a written business continuity and disaster recovery plan reasonably designed to ensure the availability and functionality of the Licensee's services in the event of an emergency or other disruption to the Licensee's normal business activities.</li>
</ul>
 
<ul>
<li>Notification of Emergencies or Disruptions. Each firm must promptly notify DFS of any emergency or other disruption to its operations that may affect its ability to fulfill regulatory obligations or that may have a significant adverse effect on the Licensee, its counterparties, or the market.</li>
</ul>
 
<ul>
<li>Transitional Period. Applications for the license will be accepted beginning on the date the proposed regulations become effective. Those already engaged in virtual currency business activity will have a 45-day transitional period to apply for a license from the date regulations become effective. The superintendent will issue or deny the license within 90 days of a complete application submission.</li>
</ul>
 
In August 2013, DFS announced its <a href="http://www.dfs.ny.gov/about/press2013/memo1308121.pdf" target="_blank">inquiry</a> into the appropriate regulatory guidelines for virtual currencies. As part of an ongoing fact-finding effort informing that inquiry, the Department held <a href="http://www.dfs.ny.gov/about/hearings/vc_01282014_indx.htm" target="_blank">public hearings</a> in January 2014. In March 2014, the Department issued a<a href="http://www.dfs.ny.gov/about/po_vc_03112014.pdf" target="_blank">public order</a> announcing it will be considering formal proposals and applications for the establishment of regulated virtual currency exchanges operating in New York.
 
To view a copy of the proposed DFS BitLicense framework, please visit, link<a href="http://www.dfs.ny.gov/about/press2014/pr1407171-vc.pdf" target="_blank"></a>. Only comments formally submitted pursuant to the SAPA process will be considered in connection with the promulgation of the proposed regulations.

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