On June 23, 2025, the New York State Department of Financial Services (“NY DFS”) issued guidance to NY DFS-regulated individuals and entities regarding the impact of “ongoing global conflicts” to the financial sector. The guidance follows a bulletin from the U.S. Department of Homeland Security about the “heightened threat environment” in the United States, which specifically references cyber attacks. The NY DFS guidance highlights three key areas of focus: cybersecurity, sanctions, and virtual currency, and may be helpful for organizations across industries globally:
- Cybersecurity. The guidance warns that escalating global conflicts have elevated cyber risk, particularly with regard to ransomware attacks and phishing campaigns. It notes that regulated entities should review their cybersecurity programs and controls to protect against these rising threats.
- Sanctions. On sanctions, it reminds U.S. persons that they are prohibited from engaging in financial transactions with persons on the Specially Designated Nationals (“SDNs”) List, unless an exception applies, and outlines steps that entities should take to facilitate compliance.
- Virtual Currency. Lastly, it flags that global conflicts increase the risk that virtual currency could be used to violate sanctions requirements. It emphasizes that regulated entities that use virtual currency must have “tailored policies, procedures, and processes” specific to virtual currency-related risks.
Click here to read the full guidance.