FOIL Request Confirmation from Open FOIL NY (DFS Investigation Finds Robinhood Crypto Failed to Maintain Effective and Compliant BSA/AML and Cybersecurity Programs)

[Gunnar Larson]

---------- Forwarded message ---------
From: <noreply at its.ny.gov>
Date: Tue, Jun 27, 2023, 6:52 PM
Subject: FOIL Request Confirmation from Open FOIL NY
To: <G at xny.io>


Thank you for submitting your FOIL request through Open FOIL NY.

Here is your Open FOIL NY confirmation information for future reference:

LARSON_DFS_20230627185237536

*INFORMATION SUBMITTED:*
*Records Requested From*
Department of Financial Services
*Short Title*
DFS Investigation Finds Robinhood Crypto Failed to Maintain Effective and
Compliant BSA/AML and Cybersecurity Programs
*Description*
Dear Madam or Sir: On August 2, 2022 the Superintendent of Financial
Services Adrienne A. Harris announced that Robinhood Crypto, LLC (“RHC”)
would pay a $30 million penalty to New York State for significant failures
in the areas of bank secrecy act/anti-money laundering (“BSA/AML”)
obligations and cybersecurity that resulted in violations of the
Department’s Virtual Currency Regulation (23 NYCRR Part 200), Money
Transmitter Regulation (3 NYCRR Part 417), Transaction Monitoring
Regulation (23 NYCRR Part 504), and Cybersecurity Regulation (23 NYCRR Part
500). xNY.io - Bank.org would like to receive any and all records related
to NY-DFS' investigation of Robinhood Crypto. Including (but not limited
to) records concerning the bespoke Supervisory Agreement Robinhood Crypto
has with the Department of Financial Services mentioned here:
https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202208021.
In addition, xNY.io - Bank.org seeks any and all records concerning New
York's approach to Robinhood Crypto and Goldman Sachs compliance programs
mandated by the United States Department of Justice, Criminal Division,
Fraud Section and Money Laundering and Asset Recovery Section mentioned
here:
https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=drivesdk.
Finally, xNY.io - Bank.org seeks records concerning New York's regulatory
approval of Robinhood Crypto engaging a fine of $30M to implement
heightened controls and additional procedures and policies relating to
electronic surveillance and investigation, due diligence on transactions or
clients and the use of third-party intermediaries across business units;
and enhancing anti-corruption training for all management and relevant
employees. Warm regards, Gunnar Larson xNY.io - Bank.org 917-580-8053
*Uploaded Files*
*FOIL Response Format*
Email
*If fees apply, please contact me if costs will be greater than*
$10000

Your FOIL request has been forwarded to the organization(s) you selected,
and the respective Records Access Officer will contact you directly for
further processing of your request. Please allow up to five business days
for such communication(s). For your convenience, here is additional contact
information:

Department of Financial Services
One State Street
20th Floor
New York, NY 10004
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