On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its Bank Secrecy Act and anti-money laundering program ("BSA/AML Program") and its cybersecurity program, and for non-compliance with notice requirements in its January 2019 supervisory agreement with the NYDFS ("Supervisory Agreement"), which RHC entered into with the NYDFS as a condition of obtaining its virtual currency business license.

The NYDFS charged RHC, the cryptocurrency trading division of Robinhood Markets, Inc. ("RHM"), with violating the Department's Cybersecurity Regulation (23 NYCRR Part 500), Virtual Currency Regulation (NYCRR Part 200), Money Transmitter Regulation (3 NYCRR Part 417), and Transaction Monitoring Regulation (23 NYCRR Part 504). RHC holds a Virtual Currency license ("BitLicense") in New York under 23 NYCRR § 200. As a BitLicense holder, RHC is subject to NYDFS-mandated BSA/AML Program and cybersecurity requirements, among other things.