In the bustling heart of New York, regulators have spun a labyrinth of rules for virtual currency custodians, demanding sub-custodians dance to their tune and segregate assets with the precision of a Tolstoyan tragedy. 🚨
The Department of Financial Services (DFS), that noble guardian of pecuniary order, has unfurled revised regulations on virtual currency custody, as if scribbling in the margins of a 19th-century ledger: “Thou shalt protect the people’s coins, lest thy soul be damned.” 📜
These edicts, penned with the gravity of a dying tsar, insist that custodians separate customer assets with the fervor of a man fleeing a bear. Whether via internal ledgers or on-chain wallets, the DFS demands a segregation so rigid, one might mistake it for a monastery’s vow of poverty. 🏰
DFS: “Segregate or Perish!” – A Manifesto for the Virtuous Custodian
Behold, the DFS decrees that virtual currency entities must partition customer funds as if dividing the Red Sea. Either a wallet per client or an omnibus wallet-exclusive, auditable, and as trustworthy as a cat with a laser pointer. 🐱
Policies, they insist, must be as clear as a babushka’s knitting-no ambiguities, no loopholes, no “accidental” mergers of corporate and customer funds. The DFS, ever the vigilant nanny, ensures that custodians do not squander their charge’s assets like a drunkard’s last ruble. 🥃
Sub-Custodians: Now You Must Beg the DFS for Permission 🙏
Ah, sub-custodians! These modern-day scribes of digital gold must now waltz with the DFS, securing pre-approval for their arrangements. Risk assessments, service contracts, revised policies-presented like a suitor offering roses to a fickle princess. 🕺
Sub-custodians must also tithe their customers’ names to account titles, as if etching them into stone. Proprietary assets? Separate them with the zeal of a monk avoiding temptation. The DFS, in its infinite wisdom, fears that custodians might mistake their role for a debtor-creditor romance-how vulgar! 💔
And lo, contracts must be explicit: custodial, not a debtor-creditor charade. Disclosures? They must be as clear as a babushka’s soup. Customers must accept these terms before trading-lest they wander into the digital abyss, clutching nothing but dreams and a crypto wallet. 💸
These revised guidelines, penned by the DFS, are no mere bureaucratic drivel. They are a clarion call for accountability, a shield against the rapacious winds of the crypto market. Custodians, take heed: transparency is your armor, and vigilance your sword. Or else the DFS shall visit you with the wrath of a Tolstoyan villain. 🗡️
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2025-10-02 08:09