News out of New York: Department of Financial Services (NYDFS) Superintendent Adrienne Harris is stepping down after four years in the role. Kaitlin Asrow, currently executive deputy superintendent of the Research & Innovation Division, will take over as acting superintendent effective October 18, 2025.
According to the announcement, over the last four years, Asrow has overseen the regulation of virtual currency companies as well as policy work on innovation and financial inclusion. During her tenure, NYDFS has brought numerous enforcement actions, increased the number of companies licensed under its “BitLicense” framework and issued extensive guidance on virtual currency matters. Just this week, the department issued updated guidance for virtual currency customer protections in the event of insolvency, noting its expectations surrounding sub-custodians and custody practices given the growth in demand for virtual currency custody services. This guidance followed another recent NYDFS notice advising all New York banking organizations engaging or considering engaging in cryptocurrency activities to follow April 2022 guidance on utilizing blockchain analytics as a compliance tool and risk identifier and mitigant.
Given Asrow’s key role in the department’s virtual currency efforts and the agency’s recent appointment of Gabriel O’Malley, a former deputy enforcement director at the Consumer Financial Protection Bureau (CFPB), to lead its Consumer Protection and Financial Enforcement Division, we expect to see a continued – if not heightened – focus on increasing its enforcement activities and regulating cryptocurrency companies.