New York’s financial regulator (NYDFS) has issued new rules: licensed crypto companies are responsible for the influencers they hire to promote their services, including impersonators. The compliance deadline is May 10, 2027.

· The materials indicate that this is new guidance for licensed virtual currency businesses, with responsibility placed on the licensed companies, not the influencers themselves.
· There is a compliance window between the guidance’s publication and May 10, 2027. The materials do not elaborate on the specific provisions.

For crypto companies licensed to operate in New York, should influencer compliance reviews have their own line item in the promotion budget?