The New York Attorney General has recently filed a series of aggressive cases against companies based outside the United States for offering cryptocurrency services to New York residents in a manner that allegedly violates New York law. For example, the AG filed actions in February 2023 against CoinEx and in March 2023 against KuCoin based on these companies allegedly offering cryptocurrency tokens for sale in New York.

While the AG describes its actions as part of an effort to “protect New York investors,” its allegations focus not on harm the foreign companies actually caused investors, but rather on the companies’ failure to comply with various registration requirements, including registering with the state of New York.