On February 7, 2018, the New York State Department of Financial Services' Superintendent issued guidance reminding cryptocurrency companies licensed in New York that are required to implement anti-fraud measures to be particularly vigilant in their efforts to prevent market manipulation. The guidance directed cryptocurrency companies to implement a written policy that identifies fraud risk, provides procedures to identify risks, allocates responsibility to monitor risk and provides for effective fraud investigations. The guidance also requires cryptocurrency companies to report immediately any discovery of wrongdoing to the Department of Financial Services, provide additional reports concerning material developments relating to the initial discovery of wrongdoing and provide a statement of actions (or proposal) to handle such wrongdoing and operations changes to be taken to avoid similar occurrences. For more information, see http://www.dfs.ny.gov/legal/industry/il180207.pdf.

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