The New York State Department of Financial Services (DFS) and the Wyoming Division of Banking signed a memorandum of understanding on October 1, 2026 to coordinate oversight of companies involved in virtual currency and digital asset activities across the two states, covering licensing, supervisory information, examinations, market trends, and potential enforcement actions.
DFS Acting Superintendent Kaitlin Asrow said interstate collaboration is essential for the virtual currency space, while Wyoming Banking Commissioner Jeremiah Bishop called it an example of two leading regulators working together to improve supervisory effectiveness.
The seven-page agreement connects two states with distinct approaches: New York operates its BitLicense framework alongside limited-purpose trust company charters, while Wyoming has developed a specialized Special Purpose Depository Institution (SPDI) regime for fully reserved banks providing custody and other digital-asset services.
New York DFS also announced the agreement through its official X account:
What the MOU Creates
The agreement establishes coordination for companies already licensed in one state seeking authorization in the other, as well as businesses applying in both jurisdictions simultaneously.
New York and Wyoming will share analysis, subject-matter reviews, and historical examination data to streamline applications, and coordinate examination schedules toward joint examinations of companies operating across both states.
| Area of Coordination | What the MOU Provides |
| Licensing | Coordination on applications in both states |
| Chartering | Exchange of relevant supervisory information |
| Examinations | Coordinated schedules and potential joint examinations |
| Enforcement | Notifications concerning potential enforcement actions |
Table 1. Main areas covered by the New York-Wyoming digital-asset supervisory agreement.
The agreement also sets a more specific process for companies that have operated under one regulator’s oversight for at least three years without an enforcement action, potentially qualifying them for a faster roughly six-month licensing review when expanding into the other state.
The agreement doesn’t create a single multistate license, and one state’s approval doesn’t carry automatic effect in the other.
Two Different State Models Are Being Connected
New York introduced its BitLicense regulation in 2015 and allows companies engaging in virtual-currency activity to obtain either a BitLicense or a New York Banking Law charter, such as a limited-purpose trust company charter, with similar safeguards but different powers.
A limited-purpose trust company can exercise fiduciary powers a BitLicensee cannot, and can engage in money transmission without a separate license. PYMNTS has reported that DFS’s early BitLicense adoption influenced the drafting of Congress’s GENIUS Act, a connection explored in Clarity Act versus GENIUS Act: what’s the difference.
Wyoming’s approach differs. Its SPDI framework was created in 2019 for a specialized form of banking focused on custody, asset servicing, cash management, and digital assets, and the state has approved four SPDI charters since accepting applications in October 2019.
Why Wyoming’s SPDI Model Requires Full Fiat Backing
The Wyoming Division of Banking says SPDIs must keep customer fiat deposits backed at 100% or more by unencumbered liquid assets, including U.S. currency and Level 1 high-quality liquid assets, and are prohibited from lending customer fiat deposits, comparable to the stablecoin backing standards covered in UK versus U.S. stablecoin regulation.
| State Regulatory Frameworks | New York | Wyoming |
| Primary digital-asset framework | BitLicense / LPTC | SPDI |
| Framework introduced | 2015 | 2019 |
| Number of SPDI charters | — | 4 approved |
| Customer fiat backing | — | 100%+ unencumbered assets |
Table 2. Selected characteristics of the regulatory structures being connected through the MOU.
The comparison illustrates why information-sharing between the two regulators can matter to companies operating across both jurisdictions.
Joint Examinations Could Reduce Duplicated Work
One practical feature is the focus on examinations. The two regulators intend to coordinate examination schedules and work toward joint examinations of entities operating in both states, sharing historical examination data and supervisory reports.
For a company subject to both states’ requirements, coordinated examinations could reduce duplicated work while giving each regulator access to the other’s information. The MOU doesn’t transfer supervisory authority, and each regulator remains responsible for businesses within its own jurisdiction.
The Agreement Extends Beyond Licensing
New York and Wyoming will also establish protocols for sharing market-trend information and enforcement-action notifications, giving each regulator a broader view of developments affecting digital-asset businesses across state lines, particularly as companies increasingly combine custody, payments, trading, and stablecoins.
The agreement also creates a formal channel for exchanging subject-matter expertise, relevant when new business models fall between established supervisory categories.
DFS Already Has a Broader Virtual-Currency Supervisory System
DFS has supervised virtual-currency businesses since before the BitLicense took effect in 2015, with its framework covering licensing, chartering, ongoing supervision, and custody requirements.
DFS has also developed specialized guidance on virtual-currency custody, stablecoin issuance, and blockchain analytics, meaning the Wyoming agreement adds another layer to an already established supervisory structure.
What Comes Next
The MOU is now the framework through which New York DFS and the Wyoming Division of Banking can coordinate licensing reviews, examinations, supervisory information, and enforcement notifications. The regulators haven’t announced a specific company that will be first to use the new arrangement.
What this means for you: New York and Wyoming have agreed to coordinate oversight of virtual-currency and digital-asset companies operating across both states. The MOU covers licensing, examinations, supervisory reports, market trends, and potential enforcement notifications, and is particularly notable because it connects New York’s BitLicense and limited-purpose trust-company framework with Wyoming’s specialized SPDI system, where customer fiat deposits must remain backed by at least 100% in unencumbered liquid assets.
This article is for informational purposes only and does not constitute financial, legal or regulatory advice. The MOU does not create a single multistate digital-asset license or replace either state’s existing laws, licensing requirements or supervisory authority.
