The New York Department of Financial Services (NYDFS) made all of the more than 3,700 comments it received regarding its BitLicense proposal available to the general public today, a move that provides new insight into the organisations and individuals that have taken an interest in the proposed regulation.
Perhaps most notably, the full release included submissions from some of the largest businesses in the US, including e-commerce giant Amazon, retail juggernaut Walmart and global remittance specialist Western Union.
The filings suggest that the BitLicense is being interpreted broadly by the legal representatives of these companies, and that greater clarity is needed by the NYDFS to indicate the entities and financial products covered under the measure.
For example, Amazon and Walmart's filings took aim at what they consider the "broad definition of virtual currency" the proposed regulation would apply in current form.
Amazon suggested the wording could be read as applicable to some of its own products, particularly closed-loop digital payment methods, prepaid value cards and prepaid cards denominated in fiat currency. Similarly, Walmart advocated for the addition of phrasing that would clearly exempt gift cards.
By comparison, Western Union submitted a much lengthier comment on the proposal, arguing that more oversight should be given to bitcoin ATM kiosks, and that more clarity should be added to the document to specify what indirect financial activities would be considered as supportive of virtual currency transmission.
"It is unclear whether operators of kiosks would be required to be separately licensed as a VC licensee, or whether any oversight or other requirements would be imposed on the physical locations that host kiosks or on the operations of the kiosks themselves," the filing reads.
Further, Western Union expressed its interest that businesses that fall under the BitLicense be made to comply with all existing anti-money laundering (AML) requirements in addition to any new measures necessary given the risks associated with virtual currency transmission.
"Western Union believes that the NYDFS' additional AML requirements for virtual currency transactions should mirror current federal AML requirements for fiat currency transactions," the filing reads. "This approach would permit VC Licensees to draw upon existing federal regulatory guidance and the knowledge of AML compliance personnel for purposes of determining how to comply with such requirements, where applicable."
The release follows superintendent Benjamin M Lawsky's November keynote address at the Money2020 conference in Las Vegas, and the many formal comments previously published in full by companies in the bitcoin space.
CoinDesk has reached out for additional comment on the filings.
Amazon image via Shutterstock