Fwd: Your Freedom of Information Law (FOIL) Request FOIL-2023-095358-021437 - DFS Investigation Finds Robinhood Crypto Failed to Maintain Effective and Compliant BSA/AML and Cybersecurity Programs

Gunnar Larson g at xny.io
Wed Jan 31 11:42:37 PST 2024

---------- Forwarded message ---------
From: <Joanne.Verdejo at dfs.ny.gov>
Date: Wed, Jan 31, 2024, 12:35 PM
Subject: Your Freedom of Information Law (FOIL) Request
To: <G at xny.io>

Good afternoon,

Attached please find correspondence from the NYS Department of Financial
Services, pertaining to your FOIL request.

Thank you.

Tracking Number:FOIL-2023-095358-021437



G at xny.io

January 31, 2024

Gunnar Larson

xNY.io Bank.org

406 West 25th Street

New York, NY 10001

Re: FOIL Tracking No. 2023-095358

Dear Gunnar Larson:

I write with respect to your above-referenced FOIL request, assigned the
tracking number 2023-

095358. The New York State Department of Financial Services (DFS) requires
additional time to

complete its response to your request.

DFS anticipates completing your request on or about March 8, 2024. We
appreciate your

continued patience.

Thank you.

---------- 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:



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


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:
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
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


If fees apply, please contact me if costs will be greater than


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

Department of Financial Services

One State Street

20th Floor

New York, NY 10004
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