NYDFS and Wyoming sign virtual-currency oversight MOU
NYDFS and Wyoming signed a virtual-currency MOU effective on September 23, ahead of the October 1 notice. The six-month aim is an endeavour, not a passport.
The New York State Department of Financial Services (NYDFS) announced a virtual-currency memorandum with Wyoming on October 1, 2026, after the text had already taken effect. The seven-page agreement commences on the last signature of the parties, September 23, 2026, when Wyoming Banking Commissioner Jeremiah Bishop signed. Acting Superintendent Kaitlin Asrow had signed on September 18. The NYDFS release is the public notice, not a passport between a BitLicense and a Wyoming charter.
The understandings will not modify either party's legal authority, will not create enforceable rights, and will not stop either side from acting alone. NYDFS and the Wyoming Division of Banking can share examination files, but one state's approval does not become the other's.
What the memorandum binds
The parties are the Wyoming Department of Audit, Division of Banking, at 2300 Capitol Avenue in Cheyenne, and NYDFS at One State Street Plaza in New York. Covered activity follows Wyoming's digital-asset statutes and "virtual currency" in 23 NYCRR Part 200, for any entity doing, or seeking, that business in either state or both. Either side may end the memorandum on 30 calendar days' written notice.
A firm already licensed or chartered in one state, including through an affiliate, can have the existing regulator send material to the other on request. The sides confer so decisions line up only "to the extent possible" under each statute. Firms applying in both states at once receive shared summaries and coordinated subject-matter reviews, not a six-month endeavour.
Who can ask for six months
The faster path has three conditions. The firm must already be licensed or chartered, must have operated under that oversight for at least three years, and must not be under an enforcement action. If the models are "sufficiently similar", the prospective regulator uses historical examination files. The text says it "shall endeavor" to decide within six months of the application date or of the date those files arrive, whichever is later. A statement of intent does not start the clock.
Firms supervised in both states get coordination rather than a deadline. The agencies will try to align examination schedules and, where practicable, examine together, but neither is expected to join exams more often than its own law requires. Each side will try to give notice before an enforcement action, and they may proceed jointly, in coordination, or separately.
Two regimes, not one standard
The October 1 release points back to the BitLicense, which NYDFS calls the nation's first comprehensive virtual-currency framework, from 2015. Wyoming's special purpose depository institution page describes fully reserved banks that may custody digital assets, may not lend customer fiat deposits, and must keep those deposits backed 100% or more by unencumbered liquid assets. The page states that the Banking Board has approved four SPDI charters and has taken applications since October 1, 2019. It does not mention this memorandum, and a search of the Division's site found no matching announcement.
Wyoming is asked to move faster only if the Cheyenne model is close to the one NYDFS already examines. A Wyoming SPDI that wants New York authorisation faces that test in reverse. The digital-assets desk has also followed Bastion's national trust bank application, Block's uninsured bitcoin trust bank and Deutsche Bank's crypto custody licence.
On June 2, 2026, NYDFS signed a memorandum with the European Banking Authority limited to stablecoin activity, which the department said does not cover other business a supervised firm may conduct. The Wyoming text is wider: it reaches Part 200 and Wyoming digital-asset activity, and it preserves sovereign immunity. Senior Assistant Attorney General Jodi A. Darrough approved the form on September 11, 2026, a step required before the memorandum could bind the Division.
"Interstate collaboration is essential for the virtual currency space," said Acting Superintendent Kaitlin Asrow. "This MOU will add to the resources and information available to each regulator, helping to facilitate responsible innovation in the market while protecting consumers across our respective jurisdictions."
Wyoming Banking Commissioner Jeremiah Bishop said: "This MOU shows the strength of the state regulatory system as an example of two leading regulators in this space working together to better the effectiveness in supervision." The release names no firm and no request to use the expedited path.
Each side is to name a liaison. The six-month endeavour runs from the later of the application and the examination file, and only for a firm three years clear of enforcement. Examiners may still decide that a Wyoming SPDI and a New York virtual-currency business are not the same model.
This article is informational analysis only and is not financial, investment, or trading advice. Cryptocurrencies are highly volatile and can lose substantial value rapidly. Past performance and historical patterns do not guarantee future results. Do your own research and consult a regulated financial adviser before making any investment decision.
Reporting by Karthik Subramanian. Filed 2 October 2026, 19:00 GMT.
Digital Assets Correspondent
Karthik Subramanian is a founder, writer, and technology consultant with nine years in the crypto ecosystem.
