Coin Center has published a detailed comparison of the revised BitLicense, released by the NY Department of Financial Services on Wednesday, with the previous version. The organisation’s leaders, Jerry Brito and Peter Van Valkenburgh, found the changes that have been made to the proposal “encouraging”.


“NYDFS has shown a willingness to embrace criticism that should be celebrated by the Bitcoin community. This new draft clearly indicates that the many comments submitted in the previous comment period were reviewed and considered,” they write in a blogpost.

Coin Center positions itself as non-profit research organisation that specialises on bitcoin and cryptocurrency policy. They see their mission in promoting a regulatory climate that would be favourable for blockchain innovations.

In the Coin Center file, the additions found in the new draft of the law are highlighted in blue and the deleted parts are crossed out in red. The comparison indicates that some sections were expanded after the comment period. In one example, definitions of ‘Gift cards’ and ‘Qualified custodians’ have been added. The new document requires licensees to provide verification from the New York State Department of Taxation and Finance that they are in compliance with all tax obligations.

Among other changes was the introduction of a two-year conditional license for those who do not meet all requirements when applying for the license. The Anti-money laundering and Cyber security programmes are described in more detail. Coin Center experts also found some changes in the definition of ‘Virtual currency Business Activity’, which now excludes “the development and dissemination of software in and of itself”.

Regarding the recording of transactions, the new draft allows licensees to collect the recipients’ personal details only “to the extent practicable”, thus making the process of gathering information easier for businesses.

“This is fundamentally important because Bitcoin and other decentralized virtual currencies are open platforms. That openness means that senders will not always know the ID of their recipients, just as you don’t always know who lies behind an email address or a website”, Coin Center’s analysis reads. “By permitting business to operate without necessarily recording recipient data when it is not provided by the customer, the DFS shows that they understand the importance of that open technology and wish to preserve it.”

Coin Center states that they still have concerns about the law and raise a range of questions about multi-sig providers, decentralised currency issuance, and exemptions granted at the discretion of the superintendent. The organisation is getting ready for a new comment period.