In the absence of a U.S. federal framework, New York’s crypto regulatory regime remains a guide for domestic and international regulators, and that includes Congress, Adrienne Harris, head of the New York Department of Financial Services, said Wednesday at Consensus 2025 in Toronto.

Harris said the process to become regulated in her state can be difficult but, she argued, New York’s high standards have proven effective.

«The proof is in the pudding when you see that FTX, Voyager, Celsius didn’t pass our test and therefore couldn’t do business in New York,» she said, naming firms that later spectacularly collapsed.

Among U.S. states, New York has been in the vanguard of crypto regulation, having established its BitLicense to regulate crypto firms, and devoting what Harris said was a 60-person staff to the work.

With Congress still working on crypto regulations, the narrow jurisdiction of the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) remains the only federal-level supervision, so the states represent the remainder of U.S. oversight of the industry.

Harris’ deputy overseeing digital assets, Ken Coghill, also appeared at Consensus on Wednesday. He said the key issue is on preventing money laundering and other financial crime. Crypto licensees and applicants often underestimate how much work it takes to become a regulated entity. Most applicants don’t make it, he noted.

«You’re not just presenting a product; you’re presenting yourself,» Coghill said. «There’s a tremendous amount of homework that needs to be done» — particularly in understanding and outlining «what the risks are that your business creates.»